The European Commission has recently taken a significant step in preparing the next phase of the Carbon Border Adjustment Mechanism (CBAM). On August 29, 2025, the Commission published three Calls for Evidence, with a submission deadline of September 25, to support the development of upcoming Implementing Acts under CBAM.

The key areas under consultation include:

1. Methodology for Calculating Emissions and Default Values
   The Commission seeks input on calculating actual emissions and defining default values, covering electricity, direct, and indirect emissions. This implementing act will determine emission factors for the definitive period; the evidence required to calculate actual emissions embedded in CBAM covered goods, and conditions for using alternative default values. This will replace the transitional rules currently established in Annex III of the Implementing Regulation.
2. Adjustment of CBAM Certificates for Free EU ETS Allowances
   The act will establish rules for adjusting CBAM obligations in sectors where EU producers benefit from free ETS allowances, which are gradually being phased out between 2026 and 2034. Importers will be able to surrender fewer CBAM certificates in these sectors. The Commission will define parameters to prevent competitive distortions between EU operators receiving free allocations and third-country operators producing the same CBAM-covered goods.
3. Deduction of Carbon Prices Paid in Third Countries
   Importers may be able to reduce the number of CBAM certificates surrendered to account for carbon costs already paid outside the EU. The consultation addresses the evidence required, the eligibility criteria for third-party verification, and the methodology for recognizing these third-country carbon costs. Once finalized, this measure ensures that importers of CBAM-covered goods are not subject to double carbon costs for the same emissions.

The draft texts will be submitted to Member State experts in the CBAM Committee in the coming months. The Committee will discuss and vote on the drafts, issuing its opinion by qualified majority. Adoption is expected in Q4 2025, after which the measures will be published in the Official Journal and enter into force. These implementing acts will follow the “examination procedure,” under which the European Parliament and Council may raise objections only if the Commission exceeds its delegated powers.

We are closely monitoring these developments to assist companies in responding to the consultation and shaping their carbon accounting approaches under CBAM. Stakeholders are encouraged to consider this an important opportunity to influence the methodology for the definitive period.