Since 1 January 2026, an importer whose total imports of CBAM goods stay at or below 50 tonnes in a calendar year is exempt from CBAM: no authorisation, no declaration, no certificates. Pass 50 tonnes and the whole year is in scope, the first tonne included.
The rule came in with Regulation (EU) 2025/2083, the simplification of the CBAM regulation, and it replaced the old exemption for consignments worth €150 or less. The Commission estimated that the threshold removes about 90% of importers from CBAM and keeps about 99% of the embedded emissions in scope. That's because most importers bring in small volumes, and most emissions arrive with a few large ones.
The 50 tonnes are one total per importer per year
The 50 tonnes are one yearly total of net mass per importer, summed across every CBAM good except electricity and hydrogen.
- Per importer. The count covers the importer's own imports. A group's other entities don't enter it, and neither does the size of each consignment.
- Per calendar year. The count restarts on 1 January.
- Across sectors. Cement, iron and steel, aluminium and fertilisers add up to one total. 30 tonnes of steel screws and 25 tonnes of aluminium profiles make 55 tonnes.
- By net mass. Packaging doesn't count.
- Electricity and hydrogen are outside the threshold. Any quantity of those two is in scope.
It's a yes-or-no test on the year. It doesn't exempt the first 50 tonnes of a larger importer.
Passing 50 tonnes brings the whole year into scope
Once the year's imports pass 50 tonnes, every tonne imported that year is in scope, including the ones that came in before the line was crossed. The importer then has to be an authorised CBAM declarant. Importing above the threshold without authorisation is a breach, and the regulation sets penalties for it above the standard €100 per tonne of CO2e.
One tonne over the line: €21,831 on steel screws from China
One tonne over the threshold turns a zero bill into certificates on the whole year. Take an importer that brings in steel fasteners, CN 7318 15 95, from China. The Commission's 2026 default value for that heading is 6.375 tCO2e per tonne, 7.013 with the 10% mark-up. The CBAM benchmark for the heading, route C, is 1.364, and in 2026 97.5% of it comes off.
| Year's imports | In scope? | Certificates | Cost at €75.28 |
|---|---|---|---|
| 40 t | No | 0 | €0 |
| 50 t | No | 0 | €0 |
| 51 t | Yes, all 51 t | 290 | €21,831.20 |
| 60 t | Yes, all 60 t | 341 | €25,670.48 |
| 200 t | Yes | 1,137 | €85,593.36 |
At 51 tonnes the importer pays on all 51, not on 1. The default sits far above the benchmark, so most of the emissions are paid for already in 2026. At the 2030 factor of 51.5%, with the 30% mark-up, the same 60 tonnes need 456 certificates, €34,327.68 at €75.28. So the line matters more every year. To see the numbers for your own code, look it up in the CN code list or read how the cost is calculated.
The authorisation deadline for 2026
An importer that expected to pass 50 tonnes in 2026 had to apply for authorised declarant status by 31 March 2026. If it applied by that date, it may keep importing while the national authority decides. If it didn't apply and then passes 50 tonnes, it's importing without authorisation. The route to the status and the filing that follows are in the CBAM declaration.
Track the count every month, per importer entity
A monthly count per importer entity shows the 50th tonne coming, so the decision is made before it lands.
- Sum the net mass of every CBAM code, every month, per importer entity. A customs broker's reports usually hold the data, split across several declarations.
- Watch the codes you don't think of as steel. Screws, nuts, washers, tubes, fittings, wire and structures of iron or steel are in Annex I. The CN code list shows all 572.
- Decide before the 50th tonne. Passing the line in November brings the whole year into scope.
- Price the year as if it's in scope. If the count is close, put the in-scope bill next to the cost of moving shipments into the next year. 51 t of Chinese screws costs €21,831 in 2026, and 50 t costs nothing.
The CBAM calculator flags every line at or below 50 tonnes. Only the importer's full-year total settles the question.
FAQ
Does the CBAM 50-tonne threshold apply per shipment?
No. It's the importer's total net mass of CBAM goods over the calendar year. A 2-tonne consignment is in scope if the year's total passes 50 tonnes.
Does the threshold apply per company or per group?
Per importer. The importing entity counts its own imports, and a group's other entities don't add to its total.
Are electricity and hydrogen covered by the 50-tonne exemption?
No. Electricity and hydrogen have no threshold, so any quantity imported is in scope.
What was the CBAM de minimis before 2026?
Consignments worth €150 or less were exempt. Regulation (EU) 2025/2083 replaced that value test with the 50-tonne mass test per importer per year.
If I pass 50 tonnes in December, do I pay only on the excess?
No. You pay on the whole year. 51 tonnes of Chinese steel fasteners in 2026 means 290 certificates, where 50 tonnes means none.
Sources: Regulation (EU) 2023/956, Article 2, as amended by Regulation (EU) 2025/2083. Commission press release on the CBAM simplification. Default values from the Commission's 2026 tables; CBAM benchmarks from Implementing Regulation (EU) 2025/2620; certificate price €75.28 for 2026 Q2, published 6 July 2026. Costs recomputed on 19 October 2026 with the CBAM Data engine.