What is the CBAM 50-tonne exemption?

A de minimis rule in Article 2(3a) of Regulation (EU) 2023/956, inserted by the Omnibus amendment Regulation (EU) 2025/2083. An importer whose total net mass of CBAM goods is 50 tonnes or less in a calendar year is exempt from CBAM reporting, declaration and certificate obligations. Hydrogen and electricity are excluded from the exemption.

Is the 50-tonne threshold per shipment or per year?

Per importer, per calendar year, cumulative across all CBAM goods combined. It replaced the earlier EUR 150 per-consignment de minimis. Individual shipment values and counts no longer matter; only the running annual net mass does.

Are hydrogen and electricity covered by the 50-tonne exemption?

No. Imports of hydrogen and electricity are subject to CBAM regardless of tonnage. The 50-tonne de minimis exemption does not apply to them, so importing any amount can create CBAM obligations.

What happens when I cross 50 tonnes?

Once cumulative annual mass exceeds 50 tonnes, CBAM obligations apply to that whole calendar year, not just the excess. An importer intending to exceed the threshold must hold authorised CBAM declarant status before doing so.

CBAM 50 tonnes exemption explained (Art. 2(3a))

Q: What is the 31 March 2026 date about?

An importer that applied for authorised CBAM declarant status by 31 March 2026 may continue importing CBAM goods above the threshold while the application is being decided. Verify the current procedure with your national competent authority.

Last reviewed 16 July 2026. Reflects Regulation (EU) 2025/2083, in force since 20 October 2025.

What the 50-tonne exemption is

The Carbon Border Adjustment Mechanism (CBAM) is the EU's carbon price on imports of certain carbon-intensive goods. Its definitive regime has applied since 1 January 2026.

The 50-tonne exemption is a de minimis rule. If your total imports of CBAM goods are 50 tonnes of net mass or less in a calendar year, you are exempt from CBAM obligations for that year: no CBAM report, no CBAM declaration, and no certificates to buy or surrender.

This threshold was introduced by the CBAM Omnibus amendment, Regulation (EU) 2025/2083, which inserted a new Article 2(3a) into the original CBAM Regulation (EU) 2023/956. It replaced the earlier transitional-period rule, which exempted consignments with an intrinsic value below EUR 150 on a per-shipment basis. That per-consignment test is gone; a single annual mass figure now decides whether you are in or out.

In one sentence: import 50 tonnes or less of CBAM goods in a calendar year and you have no CBAM obligations for that year — unless your imports include hydrogen or electricity, which are never exempt.

According to the European Commission, the threshold is designed to remove roughly 90% of importers from CBAM administration while still covering around 99% of the embedded emissions from CBAM goods. In practice, that means the rule was written for small and occasional importers, while the largest steel, aluminium and cement flows remain fully in scope.

Who the exemption applies to

The threshold is assessed per importer and per calendar year. "Per importer" means the legal entity bringing the goods into free circulation in the EU — in customs terms, the entity identified by an EORI number, not a whole corporate group.

It covers these goods categories, which are the CBAM goods now subject to the mass threshold:

Cement
Fertilisers
Iron and steel
Aluminium

Hydrogen and electricity are also CBAM goods, but the 50-tonne exemption does not apply to them — see Goods that are never exempt below.

How the 50-tonne annual count works

The count is cumulative net mass, added across all covered CBAM goods combined, over the calendar year. It is not per product category and not per shipment. Cement, fertilisers, iron and steel, and aluminium all go into the same running total.

Basis	Net mass (tonnes)
Aggregation	All covered CBAM goods combined into one running total
Per	Importer (EORI-level legal entity)
Period	Calendar year (resets on 1 January)
Threshold	50 tonnes cumulative
Excluded from the exemption	Hydrogen and electricity (in scope at any tonnage)

A worked example: an importer brings in 18 t of steel in Q1, 20 t of aluminium in Q2, and 9 t of fertilisers in Q3. The running total is 47 t — still under 50 t, so no CBAM obligations so far. A further 6 t of steel in Q4 pushes the annual total to 53 t, and the importer is now over the threshold.

Because the total is cumulative, the practical task is to keep a running tally of net mass from 1 January and know how close you are before the next order lands — not to check each shipment in isolation.

What happens when you cross 50 tonnes

Crossing the threshold has two consequences that surprise importers who expected a shipment-by-shipment rule.

1. The whole year becomes liable, not just the excess

Once your cumulative annual mass exceeds 50 tonnes, CBAM obligations apply to that entire calendar year's imports of CBAM goods — including the tonnes you brought in while still under the threshold. There is no "first 50 tonnes free" carve-out once you go over. This is why the running total matters well before you reach the line.

2. You must be an authorised CBAM declarant

Only an authorised CBAM declarant may import CBAM goods above the threshold. Authorisation is granted by your national competent authority, and it is what lets you file the CBAM declaration and buy and surrender CBAM certificates. An importer that intends to exceed 50 tonnes is expected to hold this status before crossing the threshold, not to apply after the fact.

The 31 March 2026 transitional point: an importer that applied for authorised CBAM declarant status by 31 March 2026 may continue importing CBAM goods above the threshold while the application is being decided. If you did not apply in time and now expect to exceed 50 tonnes, treat authorisation as a prerequisite and confirm the current procedure and timing with your national competent authority.

On timing of costs: the definitive regime applies to 2026 imports, but certificate sales and the first surrender obligation fall in 2027. In other words, exceeding the threshold in 2026 creates a declaration and a certificate bill that is settled the following year — a lag worth planning for even though the tonnage is counted now.

Goods that are never exempt: hydrogen and electricity

The 50-tonne exemption applies to cement, fertilisers, iron and steel, and aluminium. It does not apply to hydrogen or electricity. These two goods are in scope for CBAM regardless of tonnage, because their market structures differ from the mass-traded goods the threshold was designed for.

The practical effect: if any of your imports are hydrogen or electricity, you cannot rely on being "under 50 tonnes" to stay out of CBAM. A small volume of hydrogen or any imported electricity can create CBAM obligations on its own. If you import these goods, treat CBAM as engaged and focus on declarant status and reporting rather than on the mass count.

A register that contains hydrogen or electricity should be flagged as in scope on that basis alone — the tonnage bar for the other goods does not protect it.

Common misconceptions

"It's still a per-shipment / EUR 150 test." No. The per-consignment value test from the transitional period was replaced by the annual 50-tonne mass threshold. Value and shipment count no longer decide it.
"Each product category has its own 50 tonnes." No. The 50 tonnes is a single combined total across cement, fertilisers, iron and steel, and aluminium — not 50 t per category.
"Only the tonnes above 50 are liable." No. Once you exceed the threshold, the full calendar year's CBAM imports are covered, not just the excess.
"The threshold applies to my whole group." It is assessed per importing legal entity (EORI level), not aggregated across a corporate group. Different importing entities each have their own count — which also means group structures should not be used artificially to stay under the line.
"Being under 50 tonnes covers my hydrogen and electricity too." No. Those goods sit outside the exemption entirely.
"I can wait until I cross the line, then get authorised." Authorisation is meant to be in place before you import above the threshold, and the process is handled by your national authority rather than being instant. Plan ahead.

Keeping the running total

Because the 50-tonne figure is cumulative across a calendar year, the recurring job is simply knowing where your running net-mass total stands before the next order lands. The CBAM Import Tracker keeps that tally in your browser: log each import, watch the count against the 50-tonne line, and it flags hydrogen and electricity as in scope regardless of tonnage. It runs locally — import data is not uploaded — and it can estimate embedded emissions and indicative certificate costs from the values you enter.

Open the CBAM Import Tracker

Frequently asked questions

Is the 50-tonne CBAM threshold per shipment or per year?

Per importer, per calendar year, cumulative across all covered CBAM goods. It replaced the earlier per-consignment de minimis. Individual shipment values and counts no longer decide it — only the running annual net mass does.

Which goods count toward the 50 tonnes?

Cement, fertilisers, iron and steel, and aluminium, combined into a single annual total. Hydrogen and electricity are CBAM goods but are excluded from the exemption, so they do not "use up" the 50 tonnes — they are simply in scope on their own.

What happens the moment I exceed 50 tonnes?

CBAM obligations apply to the whole calendar year's CBAM imports, not just the tonnes above 50. To keep importing above the threshold you must be an authorised CBAM declarant, granted by your national competent authority.

Do I need authorisation before or after crossing the threshold?

Before. An importer that intends to exceed 50 tonnes is expected to hold authorised CBAM declarant status in advance. A transitional rule allowed importers that applied by 31 March 2026 to keep importing above the threshold while their application was pending.

Are hydrogen and electricity exempt if I stay under 50 tonnes?

No. The 50-tonne exemption does not apply to hydrogen or electricity. Importing these goods can create CBAM obligations regardless of tonnage.

When do the costs actually fall?

The definitive regime covers 2026 imports, but certificate sales and the first surrender obligation fall in 2027. Tonnage is counted now; the certificate bill is settled the following year.

Sources

Regulation (EU) 2025/2083 (CBAM Omnibus amendment), Official Journal — eur-lex.europa.eu
Regulation (EU) 2023/956 (CBAM Regulation) — eur-lex.europa.eu
European Commission — Carbon Border Adjustment Mechanism — taxation-customs.ec.europa.eu
ICAP — EU adopts CBAM simplifications ahead of the 2026 compliance phase — icapcarbonaction.com

This guide is general information about the CBAM de minimis threshold, not customs, tax or legal advice. CBAM rules are amended periodically and implementing acts add detail — verify the current threshold, procedure and dates against the Official Journal and the European Commission, and confirm authorisation with your national competent authority before relying on any figure. Not affiliated with the European Commission or the EU.