ACEA position on the Carbon Border Adjustment Mechanism (CBAM) simplification

ACEA position on the Carbon Border Adjustment Mechanism (CBAM) simplification

ACEA — 2025-04-28

News from Brussels

The European Automobile Manufacturers’ Association (ACEA) welcomes the Carbon Border Adjustment Mechanism (CBAM) as it will assist its members in reaching climate neutrality commitments and is a complimentary instrument to increase ambition in the Emissions Trading System (ETS).

However, the mechanism will have significant implications for our manufacturers’ market competitiveness given the increased supply chain costs that it will create. ACEA members are very cautious concerning the possibility of extending CBAM to downstream sectors that are not at risk of carbon leakage.

Due to concerns around competitiveness and the significant administrative demand that the mechanism is creating, ACEA believes the CBAM simplification is pressingly needed. In its position on CBAM simplification package, ACEA highlights six critical elements that required to be addressed to guarantee European users of CBAM goods have the means to ensure compliance.

  1. National Competent Authorities should be comprehensively empowered before regulatory elements become effective.
  2. De minimis. ACEA proposes a critical additional de minimis that could be used by registered CBAM declarants to exclude the reporting of goods of insignificant value in terms of both mass and embedded emissions.
  3. Default values. ACEA welcomes the Commission’s proposal to allow for the unconditional use of default values.
  4. Group reporting. The proposal omits to allow for group-level management of CBAM operations for companies located in several member states.
  5. Packaging. The simplification proposal should make it clear that goods already on the market and then reimported into the EU – in particular reusable packaging – are exempt from CBAM requirements
  6. Automatisation. The Commission should seek to part-automatise the reporting process through use of import declaration data.