CBAM MOVES INTO ITS FINAL PHASE – COMMISSION PUBLISHES MAJOR IMPLEMENTATION PACKAGE
On 17 December 2025, the European Commission published an extensive package of documents completing and expanding the Carbon Border Adjustment Mechanism (CBAM) framework ahead of its definitive phase starting in 2026. The package consists of 24 separate legal acts, annexes, reports and legislative proposals, all released on the same day.
The package finalises how CBAM will work in practice. They set out, among other things, how carbon emissions embedded in imported goods must be calculated and verified, how default values will be applied where data are missing, how CBAM certificates will be priced, and how the CBAM Registry and authorisation system will function. For companies importing CBAM goods into the EU, these rules translate climate policy objectives into concrete administrative and financial obligations.
Beyond implementation details, the Commission also published its review of the CBAM transitional period, concluding that the mechanism is broadly on track and should now be strengthened. In parallel, it launched new legislative proposals to extend CBAM to certain downstream products and to introduce stronger anti-circumvention measures. These proposals signal that CBAM is expected to grow in scope and complexity in the coming years, affecting a wider range of supply chains.
CLECAT will continue to analyse developments closely and keep members informed as the CBAM framework moves from design to full enforcement in 2026.