MACF/CBAM: last communications at six months of entry into force
While the MACF Regulation is still waiting to be finalized following the European Commission's proposals for relief, measures to protect affected producers in Europe are in place.
In the run-up to its definitive entry into force on 1 January 2026, the MACF (Carbon Adjustment at the Border Mechanism) continues to raise challenges for European producers: the risk of loss of export competitiveness, attempts at circumvention and administrative complexity. Here is an update on the European Commission's recent communications on simplification and protection measures for businesses.
MACF simplifications: threshold and administrative relief
On 18 June 2025, the Commission, Parliament and the Council reached political agreement on several key simplifications:
- The exemption threshold of 50 tonnes per importer per year.
- Reductions in procedures for importers above this threshold: simplification of authorisations, data collection, emission calculations, verification and use of carbon prices paid outside the EU. These measures are part of the « Omnibus I package » and should apply from the final phase of the MACF from 1 January 2026.
The European Parliament and the Council must now formally adopt the package through a publication in the Official Journal of the EU which we will forward to you as soon as it is published.
Public consultation on the extension of MACF to downstream products
On 2 July 2025, the Commission launched a public consultation on three aspects:
- Extension of the MACF to certain downstream products, including steel, aluminium and electricity – to avoid the relocation of production outside the EU to advanced processing stages.
- Updates of anti-circumvention measures to counter practices aimed at artificially avoiding MACF.
- Revision of the rules for calculating emissions in imported electricity, including balance between default and actual emissions.
It is possible to answer this question. consultation, which is addressed to all stakeholders (enterprises, associations, NGOs, researchers, authorities, trade unions) until 26 August 2025.
Measures to mitigate the risk of carbon leakage from exports:
On 3 July 2025, the Commission announced that it would propose, by the end of 2025, a new measure to reduce the risk of carbon leakage that could be generated by companies seeking to circumvent the regulation.
- This will ensure equivalent treatment between goods produced, imported or exported in the MACF sectors.
- It will enter into force for a limited period of time and will be reviewed following the reform of the quota exchange system (ETS) planned for 2026.
The aim is to avoid the shift of production to countries with environmental constraints.