Proposed CBAM Amendments

This report by the African Future Policies Hub analyzes proposed amendments to the European Union's Carbon Border Adjustment Mechanism (CBAM) introduced on 26 February 2025. While the amendments aim to reduce the administrative burden on EU importers through new volumetric thresholds and simplified default values, the report argues these changes primarily benefit EU entities and may negatively impact African exporters by increasing costs or reducing the benefits of domestic carbon pricing.

• The European Commission's proposed CBAM amendments, part of a 'simplification package' introduced on 26 February 2025, aim to reduce bureaucracy and costs for EU importers but do not intend to ease the financial or compliance burdens on exporting nations.
• A new volumetric de minimis threshold is proposed to exempt smaller EU importers; the CBAM would only apply to imports exceeding 50 cumulative tonnes per product per year. While this may slightly benefit African exporters selling to EU SMEs, the overall economic impact is expected to remain similar because 99% of embedded emissions remain covered.
• The proposed amendments do not grant the full postponement or exemptions for African states or Least Developed Countries (LDCs) that have been advocated for. Instead, they only delay the timing for surrendering CBAM certificates from the start of the definitive phase (1 January 2026) to 31 August 2027.
• Proposed changes to default values for embedded emissions would allow EU importers to choose between actual installation data and default values. This may penalize African exporters because default values typically overestimate carbon content, leading to higher costs.
• For countries with 'unreliable' data, the EU proposes changing the default value reference from the ten worst-performing EU installations to the average of the ten highest default values globally. This is expected to negatively impact exporters, such as those in Egypt, by removing the advantage of being compared to EU manufacturers who receive decarbonization support.
• To simplify carbon price deductions, the Commission proposes using default carbon prices for each country. This may disadvantage African exporters if EU importers choose the simpler default value over certified evidence of actual prices paid, potentially increasing costs for the exporter.
• A 2023 study by the African Climate Foundation and the London School of Economics and Political Science estimated that the CBAM could reduce Africa's GDP by 0.91%, which equaled a $25 billion decrease based on 2021 GDP levels.

APA

Rumble, O., & Gilder, A. (2025). Proposed CBAM Amendments. African Future Policies Hub. https://img1.wsimg.com/blobby/go/b2d05cc3-7b8c-4f0d-a62a-66af7434f28f/downloads/51cfbb88-de03-4494-91be-6902c5f4be09/AFPH%20Proposed%20CBAM%20Amendments%20Report%2021MAR.pdf?ver=1780902966035

Chicago

Rumble, Olivia, and Andrew Gilder. Proposed CBAM Amendments. African Future Policies Hub, 2025. https://img1.wsimg.com/blobby/go/b2d05cc3-7b8c-4f0d-a62a-66af7434f28f/downloads/51cfbb88-de03-4494-91be-6902c5f4be09/AFPH%20Proposed%20CBAM%20Amendments%20Report%2021MAR.pdf?ver=1780902966035.

Wikipedia

{{cite report |last1=Rumble |first1=Olivia |last2=Gilder |first2=Andrew |title=Proposed CBAM Amendments |publisher=African Future Policies Hub |date=14 March 2025 |url=https://img1.wsimg.com/blobby/go/b2d05cc3-7b8c-4f0d-a62a-66af7434f28f/downloads/51cfbb88-de03-4494-91be-6902c5f4be09/AFPH%20Proposed%20CBAM%20Amendments%20Report%2021MAR.pdf?ver=1780902966035 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{rumble2025proposed, author = {Rumble, Olivia and Gilder, Andrew}, title = {{Proposed CBAM Amendments}}, institution = {African Future Policies Hub}, year = {2025}, month = mar, url = {https://img1.wsimg.com/blobby/go/b2d05cc3-7b8c-4f0d-a62a-66af7434f28f/downloads/51cfbb88-de03-4494-91be-6902c5f4be09/AFPH%20Proposed%20CBAM%20Amendments%20Report%2021MAR.pdf?ver=1780902966035}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }