What did Regulation (EU) 2025/2083 change?
Regulation (EU) 2025/2083 of 8 October 2025, published in the Official Journal on 17 October 2025 and in force since 20 October 2025, amended Regulation (EU) 2023/956 just before the definitive period began. It eased the regime and moved the calendar, without changing the principle: the EU importer declares and pays, the operator outside the EU supplies the data.
Point | Original 2023 text | After Regulation (EU) 2025/2083 |
|---|---|---|
Exemption | Consignments of negligible value | Single threshold of 50 tonnes net mass per importer and calendar year, all CN codes combined, except electricity and hydrogen (Article 2a) |
Annual declaration and surrender of certificates | By 31 May | By 30 September, for the first time in 2027 for the year 2026 (Article 6 and Article 22) |
Certificates held at the end of each quarter | At least 80% of emissions | At least 50%, from 2027 (Article 22) |
Sale of certificates | From 1 January 2026 | From 1 February 2027 (Article 20) |
Carbon price paid outside the EU | Reduction only on proof of the price effectively paid | Also by reference to yearly default carbon prices, which the Commission may publish from 2027 (Article 9) |
Verifiers | No registration | Registration in the CBAM registry, not before 1 September 2026 (Article 10a) |
Importers that had applied for authorised CBAM declarant status by 31 March 2026 could keep importing while their authority decided (Article 17).
What applies during the CBAM definitive period?
The transitional period, from 1 October 2023 to 31 December 2025, only required reports. The CBAM definitive period, applicable since 1 January 2026, adds importer authorisation, verification of actual emissions and certificates. For your EU buyer:
- Authorisation. It must be an authorised CBAM declarant before importing, or have applied if it expects to exceed the threshold.
- 50-tonne threshold. If it goes over during the year, all its imports of that year fall under CBAM.
- 2026 emissions. They are either actual, calculated by your installation and checked by an accredited verifier, or set by default values.
- 2026 price. For 2026 emissions, the certificate price is the average of EU ETS allowance closing prices over the quarter of import; after that, a weekly average.
- Deadlines. Certificates on sale from 1 February 2027, at least 50% coverage at the end of each quarter from 2027, declaration and surrender by 30 September 2027.
The full timeline is on our CBAM consulting page for exporters.
How do default values work for Morocco?
Without verified actual data, your buyer declares the default values of Implementing Regulation (EU) 2025/2621 of 16 December 2025, whose Annex I was replaced by Implementing Regulation (EU) 2026/1740 of 20 July 2026, with effect from 1 January 2026. The mechanism, without figures:
- One table per country. The Morocco table covers cement, fertilisers, aluminium and hydrogen, but has no iron and steel rows: for those goods, as for any empty field, the table for other countries and territories applies.
- A rising mark-up. Total emissions are increased by 10% for 2026, 20% for 2027 and 30% from 2028 for cement, iron and steel, aluminium and hydrogen; by 1% every year for fertilisers.
- A planned revision. Regulation 2025/2621 must be revised in 2027 at the latest.
For a cement producer, each year without verified data therefore means a few more certificates for its buyer.
Who is affected in Morocco and Africa?
Producers of cement, fertilisers, iron and steel, aluminium, hydrogen and electricity selling to EU importers. The 50-tonne threshold removes small occasional buyers, rarely the regular customers of a cement plant or an aluminium profile maker. The same logic applies to suppliers in Egypt, Nigeria or South Africa, with their own country table where one exists.
- Operator registry. At the request of the operator of an installation outside the EU, the Commission registers it and its installation in the CBAM registry for five years. The O3CI module lets you upload your emissions data once and share it with each declarant, who must give you its EORI number.
- Verifiers. According to the Commission, only national accreditation bodies of EU or EEA countries accredit CBAM verifiers. Its timeline has verifiers registering from September 2026 and issuing the first verification reports in January 2027; the state of play of accreditations is published in a document dated 9 November 2026.
Your EU buyers also ask for traceability data? See our brief on the EU Deforestation Regulation (EUDR).
What should exporters do in the next 90 days?
- Now: question each EU buyer. Is it an authorised CBAM declarant, is it above the threshold, will it declare your actual emissions or default values for 2026?
- Before the end of the calendar year: close your 2026 data. Fuels, laboratory analyses, electricity for cement and fertilisers, precursors, production by CN code: every figure linked to its evidence.
- Before 1 January 2027: answer your UK buyers. Decide whether you will send them verified emissions under the UK CBAM.
- From January: book an accredited verifier. The first reports are expected in January 2027; every exporting installation will want the same slots.
- Before 1 February 2027: share the data. Register the operator and installation in O3CI, or agree another channel, so your buyer knows how many certificates to buy.
- Before the end of the first quarter of 2027: plan for coverage. Your buyer must hold certificates for at least 50% of the year’s imports, based on default values without the mark-up or on its previous surrender. Give it your forecast volumes.
What about the UK CBAM from 1 January 2027?
The United Kingdom applies its own mechanism from 1 January 2027: a tax paid by the importer. According to GOV.UK (page updated 9 September 2026), it covers aluminium, cement, fertilisers, hydrogen, and iron and steel, without indirect emissions at the start, and only importers of £50,000 or more of these goods over twelve months reach the registration threshold. A foreign producer is involved only if it chooses to supply its data.
The Emissions and Verification Regulations 2026, in force on 1 January 2027, require a verifier that is independent and accredited for the type of good. A question about your installation? Contact us.