CBAM Implementation Package Published And Proposals For Future Expansion

On 17 December 2025, the European Commission published a long-awaited suite of implementing legislation and guidance for its Carbon Border Adjustment Mechanism (which we recently covered in our previous LawNow (from 1 December 2025). This development comes less than 2 weeks before CBAM's definitive phase commences on 1 January 2026. Alongside the new legislation, the Commission also published a report on the CBAM transitional phase, a wide-reaching proposal to significantly expand the scope of CBAM to include further downstream goods from 2028, and solutions to close enforcement loopholes.

The publication of the implementation package will give businesses much-needed clarity on how the new carbon tax will be imposed - although this leaves little time to make changes in advance of the start of the measure's definitive phase, on 1 January 2026.