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The CBAM 50-tonne threshold: who is exempt, and what happens when you cross it

By Dr Tanzeel Ur Rashid, PhD (Energy), PE (Mechanical) · Published 2026-10-26 · Updated 2026-10-26

Small importers are exempt from CBAM, but the threshold is per year and per importer, and crossing it brings the whole year into scope.

Key points
  • 50 t net mass per importer per calendar year.
  • Steel, aluminium, cement and fertilisers count together.
  • Cross it once and the whole year is in scope.
  • Hydrogen and electricity are always in scope.

The rule

Since the 2025 simplification (Regulation (EU) 2025/2083), CBAM has one mass threshold: 50 tonnes of net mass per importer per calendar year, added up across cement, iron and steel, aluminium and fertilisers. It replaced the old €150-per-consignment rule.

An example

An importer brings in 30 t of screws (CN 7318) in March and 25 t of aluminium profiles (CN 7604) in November. The yearly total is 55 t, so the whole year is in scope: all 55 t need authorised-declarant status, embedded emissions and certificates, including the March screws. Track the cumulative tonnage from January, not shipment by shipment.

What to do if you are near the line

  1. Add up net mass across all four sectors from 1 January, per EORI.
  2. If you may cross 50 t, apply for authorised CBAM declarant status before the import that crosses it.
  3. Keep supplier emissions data ready for every line, since the whole year counts once you are in.

The CBAM Compliance de-minimis check tracks this for you. For values per product, see the official default values by CN code.

Frequently asked questions

What is the CBAM 50-tonne threshold?

Importers below 50 tonnes of net mass a year, added up across cement, iron and steel, aluminium and fertilisers, are exempt from CBAM obligations for that year (Regulation (EU) 2025/2083).

What happens if I cross 50 tonnes?

The whole calendar year comes into scope: every tonne imported that year, not only the excess.

Do hydrogen and electricity count toward the threshold?

No. They never count toward the 50 tonnes, and importing them is always in scope.

Figures come from the official EU data shipped with CBAM Compliance and from its calculation engine, as of 2026-10-26. Not legal advice.