EU CBAM explained for Indian exporters: what it is and how to prepare
A plain guide to the EU Carbon Border Adjustment Mechanism as of October 2026: covered goods, the 2026 definitive period, the 50-tonne threshold, default and actual values, CBAM certificates, proposed changes, and a checklist for Indian MSME exporters.
What changed with the 2025 simplification ("Omnibus")?
In February 2025 the Commission proposed simplifying CBAM as part of its Omnibus package. The result is Regulation (EU) 2025/2083 of 8 October 2025, published in the Official Journal on 17 October 2025 and in force from 20 October 2025. Main changes, as described by the Commission and the European Parliament:
- 50-tonne threshold: an importer bringing in 50 tonnes or less of CBAM goods per calendar year (by net mass) does not need authorisation and has no CBAM obligations. This replaced the earlier exemption for goods of negligible value. The Commission expects it to exempt about 182,000 importers, mostly SMEs and individuals, while still covering over 99% of in-scope emissions.
- Not for electricity and hydrogen: importers of these must always be authorised declarants.
- Cliff, not allowance: if an importer goes above 50 tonnes in a year, all CBAM obligations apply to its imports.
- Later deadlines: the annual declaration and surrender moved to 30 September of the following year, and certificate sales start on 1 February 2027.
- Lower quarterly holding: the share of certificates that must be held each quarter is 50%.
- Simpler rules for authorisation, emissions calculation and verification.
The Commission checks the threshold every year. Its assessment published on 30 September 2026 found that, for April 2025 to March 2026, the threshold would exempt 0.87% of embedded emissions, below the 1% limit.
Important for exporters: the 50 tonnes is counted per EU importer, across all its suppliers, not per Indian exporter. A small Indian exporter selling to a large EU importer will still be inside CBAM.
Sources: European Commission, Carbon Border Adjustment Mechanism (CBAM) Questions and Answers, last updated 15 October 2026; European Commission, Carbon Border Adjustment Mechanism (main page); European Commission, CBAM definitive regime; European Commission, CBAM legislation and guidance; European Commission news: Officially published: Simplifications for CBAM (20 October 2025); European Commission news: CBAM successfully entered into force on 1 January 2026 (14 January 2026); European Commission, CBAM communication and news; European Commission, Price of CBAM certificates; European Parliament press release: CBAM: Parliament adopts simplifications (10 September 2025); Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism (EUR-Lex); Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956 (EUR-Lex); European Parliamentary Research Service: Extension of CBAM scope to downstream goods and anti-circumvention measures (7 September 2026); Ministry of Commerce and Industry, India's Free Trade Agreements (2025-26): Key Highlights
This article was prepared with AI assistance and checked by the GreenEye team against the sources shown in each section.
Want to understand this for your home or company?
Talk to us. We are happy to explain what this means for you in plain words. We do not sell carbon credits and we cannot promise any result, but we can help you think it through.
Talk to usShare this article




