What the April 2025 regulatory shift means-and how Flexport helps you stay compliant

We know compliance with evolving EU regulations like the Carbon Border Adjustment Mechanism (CBAM) can feel overwhelming-especially for small and mid-sized importers. That's why we’re keeping close tabs on every policy shift, so you don’t have to.

This week, there’s good news.

On April 15, 2025, the Dutch Emissions Authority (NEa) introduced two significant updates to CBAM requirements-both designed to reduce the burden on lower-volume importers during the transitional phase (which runs until December 31, 2025). Here's what’s changed and what it means for your supply chain.

No Reporting Required for Imports Under 50 Tons Annually

Under previous rules, CBAM reporting was triggered when a shipment exceeded €150 in value. The NEa is replacing that value-based threshold with a volume-based exemption:

If your total annual imports of CBAM regulated goods are below 50 metric tonnes per annum, you no longer need to file CBAM reports.

This applies to regulated products like steel, aluminum, cement, fertilizers, and more.

For many smaller businesses, this change means fewer hours spent on paperwork, and no need to invest in costly emissions reporting systems-without compromising the EU’s climate goals.

At Flexport, we can help you monitor your import volumes and ensure you stay below this new threshold if it applies to your operations.

No Need to Report Actual Emissions Data

If you're importing more than 50 Tonnes per annum and still fall under CBAM reporting requirements, there’s more flexibility now:

• You can use default emission values provided by the EU
• You’re no longer required to collect or justify actual emissions data
• Reports will not be considered incomplete if actual data is missing

This simplification reduces complexity and makes compliance more accessible-especially for importers relying on multiple overseas producers.

The NEa made these changes to address concerns from the trade community: too many small-volume importers were getting caught in a regulatory net designed for high-emissions flows.

By focusing on tonnage instead of value, and removing emissions data obligations, the updated rules aim to:

• Improve compliance efficiency
• Lower the cost and burden for small and medium businesses
• Keep the CBAM rollout on track while fine-tuning enforcement

Immediate Actions for Importers

Your CBAM Compliance Roadmap

1. Evaluate Your Import Volumes
   Confirm whether your imports are subject to CBAM requirements.
   -Under 50 tonnes annually? No reporting obligations at this stage, simply continue monitoring.
   -Over 50 tonnes? Use the EU’s default emissions values to streamline compliance without plant-level data collection.
2. Engage Expert Support
   Need clarity on your obligations? Flexport’s customs and regulatory advisors can assess your import profile and guide you through the necessary steps.
3. Plan for the Transition Period
   These measures apply immediately and cover the CBAM transitional phase through December 31, 2025. Mandatory carbon cost payments begin on January 1, 2026.

Stay Informed, Stay Compliant

Flexport Key Insights on CBAM

• Steel Yourself for CBAM: Climate Regulations for Trade
  Why CBAM matters and how it will reshape global trade.
• CBAM Legislation Moves Forward: Coverage Expanded
  Details on the widened scope and what goods are now included.
• The Way Ahead
  Your game plan for navigating the transitional phase-and preparing for 2026.