2 October 2026 – Automotive industry association ACEA wants less CBAM bureaucracy. Yet the ERCST study it co-funded does not quantify any real relief, focuses on the expansion from 2028 and leaves SMEs with almost nothing. The fact that the funder is not even mentioned in the study is, at the very least, unfortunate.
New CBAM Study: Relief from 2028, but Not for SMEs
Automotive industry association ACEA wants less CBAM bureaucracy for European manufacturers. The underlying study, however, mainly lays the groundwork for the next expansion of the carbon border mechanism.
The intention is right. Anyone importing steel and aluminium into the EU has been dealing since January with a reporting system that treats a box of screws like a coil. ACEA, together with machinery association VDMA and suppliers’ association CLEPA, deserves credit for putting real import data on the table. But the study does not appear to deliver what ACEA’s headline, “Reducing the administrative burden for European manufacturers”, promises.
Lots of Counting, No Cost Calculation
Brussels think tank ERCST proposes adding a second exemption to the existing 50 tonne threshold: supplier relationships involving less than one tonne per year would remain exempt.
The study does not quantify what this would save in euros or working hours. It only counts exemptions. The authors themselves describe the current relief as “modest”. ACEA, meanwhile, speaks of a “massive” burden that would now be reduced. According to our calculations, based on the ERCST sample, the proposal would affect barely 1.7 per cent of all companies subject to CBAM.
The Real Target Is the 2028 CBAM Expansion
The proposal only becomes significant if the carbon border mechanism is expanded from 2028, as proposed by the Commission, to vehicle parts, engines and machinery. At that point, the number of supplier relationships for large corporations multiplies.
The study offers nothing to address today’s substantial financial burden, mark ups on default values or the effort required to obtain actual emissions data from major suppliers.
Almost Nothing for SMEs
Companies importing less than 50 tonnes are already exempt. Anyone above that threshold becomes liable for the carbon tax on every tonne and must bear the substantial administrative burden of authorisation, registry obligations, the annual declaration and certificate purchases. An SME might save a few reporting lines for small parts.
Worse still, the new exemption uses up the limited room the legislation allows for exemptions. If coverage falls below 99 per cent, the 50 tonne threshold would have to fall as well. Once again, small companies would pay the price.
Transparency Starts With the Funder
The fact that ACEA co-funded the study appears in the association’s press release, but not in the ERCST report. A look at the think tank’s funders helps explain the perspective: oil companies, utilities, chemicals, cement and aluminium. There is no genuine SME association among them. Anyone recommending rules to the Commission should disclose who commissioned and paid for the study.
Anyone who genuinely wants to relieve Europe’s industry should start not with the corporations of 2028, but with the small and medium sized enterprises of today. The prospect of CBAM bureaucracy costs rising to more than €80,000 per year from 2028 may matter little to large corporations. For many SMEs, however, it can be a question of survival.
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