CBAM/MACF: simplifications being adopted, the good news small importers have been waiting for?

MyTower
The carbon adjustment mechanism at the EU's borders (MACF)

On September 10, 2025, the European Parliament voted in favor of a simplification of the MACF/CBAM application principle. The aim is to lighten the burden on small importers without reducing the mechanism's impact on the climate.

In concrete terms, what will this change for operators? The main change concerns the principle of the 'de minimis' threshold. Until now, exemption was based on the value of the shipment (≤ €150), with the risk of circumvention through artificial splitting of imports. The text changes this value-based principle to an annual threshold based on mass.

From now on, if the cumulative net mass of your imports under MACF (cast iron/iron/steel, aluminum, cement, fertilizers) does not exceed 50 tons per calendar year, you are exempt from all obligations (authorization, declaration, purchase/refund of certificates). This exemption must be indicated on the customs declaration.

This overhaul has a major impact: it exempts the vast majority of importers (90%), while keeping almost 99% of emissions within the MACF's scope. In other words, the administrative simplification targets small volumes, without emptying the tool of its substance.

Two points to bear in mind: - Electricity and hydrogen are outside the scope of the "de minimis" exemption. They remain subject to the MACF regardless of quantity. - If you exceed the 50-tonne threshold at any time during the year , all your imports for the year fall under the MACF regime for the whole year (authorization, declaration, certificates).

What if I exceed (or risk exceeding) the threshold? Plan ahead and apply for MACF declarant authorization before you exceed 50 tonnes. In 2026, if the application is submitted no later than March 31, 2026, you can continue to import on a provisional basis, pending the competent authority's decision.

Updated declaration timetable: the MACF declaration becomes annual and must be filed by September 30 N+1 (first deadline: September 30 2027 for 2026 imports).

Adoption status: measure adopted by Parliament and awaiting publication in the Official Journal of the European Union. Stay tuned for the latest measures on this subject.

Article written by Jean-Marc Vandenbussche, Customs Consultant at MyTower

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