Omnibus Starting with the EU Omnibus initiative, this is described as a simplification package to streamline sustainability legislation by aligning timelines, definitions, and reporting obligations across multiple frameworks. The main simplification is that only importers with an annual import volume of over 50 tonnes of CBAM wares will have reporting obligations 1. In theory, this should reduce the administrative burden for both CBAM and other related regulations, such as the CSRD. In practice, however, Omnibus has highlighted a more uncomfortable truth, that most organisations are still struggling with the basics. About 18,000 importing companies are expected to fall within the scope of the regulation. As of January 14th, about 12,000 companies have applied and only 4,100 have obtained authorisation. 2 It is not only among the importers where readiness remains uneven. Many suppliers outside the EU are unfamiliar with European carbon accounting rules, lack third-party verification, or have poorly documented production routes from an emissions perspective. There has also been a severe lack of assistance from the European Commission. Very few tools are available to suppliers seeking to export CBAM wares into the EU, and the ones that do exist are difficult to navigate. Omnibus tries to alleviate this by allowing the default values to be used from the transitional phase. Their use is discouraged because the default values are based on the exporting company’ s national average, increased by a proportional markup, which in turn leads to higher costs for the importer. 3 This simplification has bought some time for many importers. Still, the decision on such a simplification will not be apparent
About the company
Josef Samak is ESG Specialist at HARALD PIHL, Europe’ s leading supplier of high-performance metal alloys. Founded in 1912, the familyowned company has long served some of the world’ s most demanding industries- including aerospace, energy, and medical technology- with materials engineered to perform in extreme environments. Sustainability is an integrated part of HARALD PIHL’ s governance and risk management framework. This work is led by ESG Specialist Josef Samak, a civil engineer educated at KTH with an MSc in Energy Systems. Josef is responsible for CBAM declarations, sustainability reporting, and broader compliance initiatives. until the end of the year, when the CBAM certificates shall be surrendered, and the true cost is revealed. However, for many importers, the cost of CBAM is secondary compared to the changes in tariffs.
Tariffs On 1 October 2025, the European Commission( EC) announced that when the current trade agreements expire in mid-2026, the current import quotas would be effectively halved while tariffs would be almost doubled, from 25 % to 50 % 4. The reasoning has been to protect the European steel industry against the general overcapacity on the global market. The market has since reacted with urgency. Many quarterly quotas for various steel product groups from China, Turkey, and India were instantly filled within the first weeks of 2026. 5
Are global markets becoming less open? From the EU perspective, CBAM is framed as a climate measure rather than a trade barrier. Yet its effects are undeniably structural. Market access increasingly depends not only on price and quality, but on regulatory alignment, data availability, and environmental performance. At the same time, CBAM is not an isolated instrument. The EU has signalled a tougher stance on trade defence, including discussions around increased tariffs and strategic autonomy in critical materials. Sustainability, security of supply, and industrial policy are converging. This trend is not uniquely European, with other countries responding in kind. China’ s Ministry of Commerce( MOFCOM) issued Announcement No. 79, tightening export controls and compliance requirements for certain categories of materials and technologies, including many steel products. 6 Similarly, the Bureau of Indian Standards( BIS) issued stricter quality control requirements for the import of steel and other input materials. 7 While these regulations differ in character, they share a similar intent. The combined effect of CBAM, EU trade measures, and non-EU regulatory responses is a gradual thickening of borders. Trade does not stop, but it becomes more conditional, and compliance capabilities become a competitive advantage.
What this means for the metals value chain For buyers and distributors, the implications are becoming clear. Supplier selection can no longer be based solely on specification and price. Carbon intensity, documentation quality, and regulatory responsiveness are becoming procurement criteria. The concept of risk management also evolves in response to the volatility of the regulatory landscape. Previous best practices usually revolved around the risk of a single source, which, if disrupted, could disrupt supply lines. Today, however, the risk is less that a single factory or supplier is incapacitated, and more that a whole country or even continent is subject to serious restrictive measures. This risk is particularly evident in niche segments such as highperformance alloys, where there are few manufacturers, and many are concentrated in specific regions. In these markets, the ability to work closely with suppliers, interpret evolving regulations, and translate them into actionable procurement decisions is becoming increasingly valuable. Strong regulatory competence, close supplier relationships, and access to a diversified global supplier base are critical to maintaining compliant and resilient supply chains.
References
1 https:// finance. ec. europa. eu / news / omnibuspackage-2025-04-01 _ en
2 https:// taxation-customs. ec. europa. eu / news / cbam-successfully-entered-force-1- january-2026-2026-01-14 _ en
3 https:// eur-lex. europa. eu / legal-content / EN / TXT / PDF /? uri = OJ: L _ 202502083
4 https:// www. reuters. com / markets / commodities / euplans-cut-steel-import-quotas-hike-tariffs-2025-10-01 /
5 https:// eurometal. net / eu-steel-import-quotas-forsome-steel-products-have-been-reached-full-capacity /
6 https:// www. reuters. com / world / asia-pacific / china-require-export-licences-some-steelproducts-2025-12-12 /
7 https:// www. certification-india. com / en / india-tightensbis-requirements-for-imported-steel-and-inputmaterials-under-qco-compliance-framework /
Next issue …
In the next issue, we will make a deep dive into the actual reporting, its administrative burden, costs, and the difficulties of re-entry.
www. stainless-steel-world. net Stainless Steel World March 2026 35