
29 May 2026 – The EU CO2 tax CBAM has been active for five months, and the nearly 3,000-page mega-bureaucracy monster is still full of errors. SME: Think Small First – critical questions from the European Parliament to the Commission.
CBAM: Five Months, 3,000 Pages, Zero Corrections
CBAM has been in force since January 2026. Since then, we have repeatedly had to report on the same problem: incorrect default values, without which numerous origins cannot be captured mathematically. Corrections: none.
The Commission regularly updates its CBAM FAQ – most recently on 28 May 2026. The known errors in the default values do not appear there. Yet these exact values are among the most frequently asked questions from affected companies.
The answer from the responsible DG TAXUD to repeated calls for corrections: “In due time.” After five months, this period apparently has still not expired for the Commission.
SME: Think Small First – Critical Questions to the Commission
“Think Small First” has been a declared principle of EU legislation for years. The reality looks different – something that was, and still is, clearly visible in the introduction of CBAM and steel tariffs, for example.
Swedish MEP Jörgen Warborn, EPP, has now formally asked the Commission how it ensures that SME concerns are genuinely incorporated into legislative procedures at an early stage – and not merely ticked off afterwards as a side issue through impact assessments.
Growing Complexity of EU Legal Acts
The background is the growing complexity of EU legal acts: basic regulations are overlaid by dozens of delegated and implementing acts, which are simply not manageable for companies without a legal department.
SMEs Have Been Ignored by the Commission for Years
In COM(2026)0380, the Commission once again commits itself to the principle. The MEP’s questions aim to determine whether concrete mechanisms stand behind this – or whether it is merely lip service.
The third question is particularly sharp: whether the Commission intends to change its approach when drafting new legislation so that the situation of SMEs serves as the starting point, and any additional requirements for large companies are justified separately.
We are very curious to see the Commission’s answer to “SME – Think small first”.
Thorsten Gerber, CEO of the Gerber Group, said today: “I would very much welcome it if Germany’s federal CDU were to engage just as intensively on the issues of small and medium-sized enterprises, CBAM, and steel tariffs. But looking at the CDU’s answers from Berlin, despite its knowledge of the serious circumstances, one could come to the conclusion that there are no small- and medium-sized enterprises in Germany worth protecting.”
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