Jamie Mcleod at IREPAS: EU is taking steps to simplify CBAM but not weakening it
Speaking at the SteelOrbis Spring 2025 Conference & 92nd IREPAS Meeting taking place in Athens on April 27-29, Jamie Mcleod, director at consulting firm Crowe U.K. LLP, talked about the EU’s Carbon Border Adjustment Mechanism (CBAM) which is in its transition period right now, stating that in January 2026 the definitive period starts, imposing a levy on carbon-intensive goods imported into the EU, with steel being the most affected good.
Mr. Mcleod said that the transitional period is only the reporting phase and the 5th quarterly report is due to be submitted in April, marking the third report requiring actual emissions data, as default values are no longer permissible for the rest of the transition period.
He underlined that obtaining reliable and complete actual emissions data remains a significant challenge. If actual data is unavailable, CBAM declarants must demonstrate that they have made all possible efforts to obtain it.
Regarding the CBAM, Mr. Mcleod stated that, apart from the obvious results, another practical result of the mechanism is that it will generate billions of revenues for the EU.
The EU is taking steps to simplify the CBAM but is not weakening it. He went on to say that the EU is proposing a mass-based threshold of 50 mt per importer per calendar year, meaning that, if an importer imports 50 mt for the whole year, they will be exempt from CBAM obligations. However, he noted, most steel importers will be over that threshold.
He warned that, from 1 January 2026, only authorised CBAM declarants can import CBAM goods into the EU.
If you are supplying to EU, you need to be authorized and applicants must have a strong compliance history, no customs debts, sufficient financial standing to meet their CBAM obligations, and suitable internal processes to demonstrate adequate CBAM management.
While EU importers are directly responsible for CBAM reporting and charges, the CBAM impacts the whole supply chain, the Crowe U.K. official pointed out.
Touching upon the UK’s CBAM, Mcleod indicated that it will come into effect in 2027 and that there will not be a transition period, adding that alignment between the UK and the EU could mitigate trade impacts for trade of CBAM goods between the parties.
