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. It needs no authorisation, files no declaration and buys no certificates. The rule came in with Regulation (EU) 2025/2083, the simplification of the CBAM regulation, and 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. Most importers of CBAM goods bring in small volumes. Most emissions arrive with a few large importers.
Counting the 50 tonnes
- Per importer. The count covers the importer's own imports. A group's other entities and the size of each consignment do not enter it.
- Per calendar year. The count restarts on 1 January.
- Across sectors. Cement, iron and steel, aluminium and fertilisers add up into one total. 30 tonnes of steel screws and 25 tonnes of aluminium profiles make 55 tonnes.
- By net mass. The weight of the goods, not of packaging.
- Electricity and hydrogen are outside the threshold. Any quantity of those two is in scope.
The threshold is a yes-or-no test on the year. It does not exempt the first 50 tonnes of a larger importer.
What happens when an importer passes 50 tonnes
If the year's imports pass 50 tonnes, the whole year is in scope, including the tonnes imported before the line was crossed. The importer then needs 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.
Take an importer that brings in fasteners, CN 7318 15 95, from China. In 2026 the default value for that heading is 6.375 tCO2e per tonne, 7.013 with the mark-up.
| Year's imports | In scope? | Certificates | Cost at €75.28 |
|---|---|---|---|
| 40 t | No | 0 | €0 |
| 50 t | No | 0 | €0 |
| 60 t | Yes, all 60 t | 11 | €828 |
| 200 t | Yes | 36 | €2,710 |
At 60 tonnes the importer pays on all 60, not on 10. The cost is small in 2026 because the CBAM factor is 2.5%. At the 2030 factor of 48.5%, and with the 30% mark-up, the same 60 tonnes need 242 certificates, about €18,000 at today's price.
The authorisation rule for 2026
An importer that expected to pass 50 tonnes in 2026 had to apply for authorised declarant status by 31 March 2026. An importer that applied by that date may keep importing while the national authority decides. An importer that did not apply, and passes 50 tonnes, is importing without authorisation. The route to the status and the filing that follows are in the CBAM declaration.
How to stay in control of the count
- 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 do not 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 in scope. If the count is close, authorisation at a 2.5% factor often costs less than managing shipments around the line.
The CBAM calculator flags every line at or below 50 tonnes. Only the importer's full-year total settles the question.
Sources: Regulation (EU) 2023/956, Article 2, as amended by Regulation (EU) 2025/2083. Commission press release on the CBAM simplification. Costs computed on 16 September 2026 with the CBAM Data engine.