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New EU environmental taxes

On 27 May 2020, the European Commission presented a proposal for a major recovery plan “Next Generation EU” (NGEU) worth EUR 750 billion, which became part of the long-term EU budget.

New taxes

The largest incentive package ever funded from the EU budget introduced new fiscal instruments. The most discussed measures are the carbon border adjustment mechanism (the “carbon duty”), the digital levy, the financial transaction tax, the market access tax and the levy on non-recycled plastic packaging waste.

Carbon Border Adjustment Mechanism (CBAM)

What we expect

On February 26, 2025, the European Commission adopted a package of proposals called the “Omnibus package,” which includes amendments to the CBAM regulation. Significant planned changes include for example:

- the introduction of a new cumulative threshold of 50 tons annually per importer, 

- the simplification of CBAM rules with a focus on the authorization process for declarants, and rules for calculating emissions

- the postponement of the start date for the sale of CBAM certificated from January 2026 to February 1, 2027

- the postponement of the deadlines for the submission of CBAM declarations and the surrender of CBAM certificates from May 31 do August 31.

These proposals still need to undergo the approval process and will be submitted to the European Parliament and the Council of the European Union for consideration and adoption.

 

What will the impact be?

Companies subject to the CBAM regulation are still required to submit quarterly reports until the end of 2025, even if they do not expect to exceed the proposed cumulative threshold. However, as part of the planned changes, it is recommended that companies not reaching the required limit of 50 tons of imported goods wait until September 2025 to apply for the status of authorised declarant.

We will continue monitoring this topic and keep you informed about developments in this area and legislative processes at both the European and national levels. If you have any questions, do not hesitate to contact our experts.