The CBAM de minimis rule is one of the most misunderstood parts of Regulation (EU) 2023/956 (CBAM Regulation). Many importers assume that if they import small volumes, they are automatically outside scope. That assumption is partly correct, but the details of how the threshold works catch importers out regularly.
What the 50 tonne threshold actually says
Following the Omnibus amendment (Regulation (EU) 2025/2083) to the CBAM Regulation, the obligation to obtain CBAM certificates and submit an annual declaration does not apply to importers whose total imports of covered goods in a calendar year do not exceed 50 tonnes of net mass. This single mass-based threshold replaced the earlier EUR 150 per-consignment exemption from the transitional phase.
The threshold is cumulative. You add up the net mass of all your covered goods together, not category by category. If you import 40 tonnes of steel and 40 tonnes of aluminium, that is 80 tonnes in total, which is over the threshold, even though each category on its own is under 50 tonnes. The threshold covers cement, fertilisers, iron and steel, and aluminium; electricity and hydrogen are not subject to it.
Regulation (EU) 2025/2083 (CBAM Omnibus) replaced the transitional EUR 150 per-consignment exemption with a single mass-based threshold: 50 tonnes of net mass of covered goods per importer per calendar year, applying from 2026. A narrow carve-out remains for non-commercial goods carried by travellers.
How to count the 50 tonnes
You count the total net mass of all your covered CBAM goods imported across every consignment in a calendar year. A shipment of 5 tonnes in January and another of 48 tonnes in October puts you at 53 tonnes for the year, which exceeds the threshold.
The counting is prospective. You need to monitor your imports throughout the year. If you breach 50 tonnes mid-year, CBAM obligations apply from that point forward for the rest of the year, and you will need to register as an authorised declarant before you can submit further import declarations for that commodity.
Which goods count toward the threshold
The CBAM Regulation covers six categories. The 50 tonne mass threshold applies to four of them, cumulatively: cement, fertilisers, iron and steel, and aluminium. Electricity and hydrogen are not subject to the mass threshold and are treated separately. Within each category, specific CN codes are listed in Annex I of the Regulation.
| Category | Example CN codes | Counts toward the 50 t total? |
|---|---|---|
| Iron and steel | 7208, 7209, 7210 series | Yes |
| Aluminium | 7601, 7604, 7606, 7608 series | Yes |
| Cement | 2523 | Yes |
| Fertilisers | 3102, 3105 series | Yes |
| Electricity | 2716 | No (treated separately) |
| Hydrogen | 2804 10 00 | No (treated separately) |
You aggregate the net mass of all goods in these four categories together against the single 50 tonne threshold. You do not assess each category, or each CN code, individually.
Exemptions that apply regardless of volume
Even if you exceed 50 tonnes, certain imports are outside CBAM scope entirely:
- Goods originating from Iceland, Liechtenstein, Norway, and Switzerland are exempt because these countries are part of or linked to the EU Emissions Trading System (EU ETS).
- Non-commercial goods imported by travellers where the value does not exceed EUR 150 per consignment.
- Goods imported for armed forces under specific conditions.
For the country-of-origin exemptions, the origin determination follows standard EU customs rules. If goods are manufactured in a non-exempt country but shipped via Norway, they do not qualify for the exemption.
What happens if you exceed the threshold
Once your total covered imports are above 50 tonnes in a calendar year, you must register as an authorised CBAM declarant via the CBAM Registry, which is managed by the European Commission. You cannot submit import declarations for CBAM goods above the threshold without this registration.
At the end of each calendar year, you must submit an annual CBAM declaration covering all CBAM goods imported during that year, report the embedded emissions in those goods, and surrender CBAM certificates corresponding to the declared embedded carbon. If you miss the 30 September deadline for the annual declaration, penalties of EUR 100 per tonne of CO2 equivalent not covered, with multipliers up to five times that amount depending on gravity and duration, apply under Article 26.
Practical advice for borderline cases
If your annual imports hover near 50 tonnes for a CBAM category, build in a margin. Temporary spikes in demand, a larger-than-expected shipment, or a delayed delivery that pushes into a new calendar year can all tip you over. Registering as an authorised declarant before you hit the threshold is always cheaper than scrambling to comply after the fact.
If you are consistently well below 50 tonnes and have no plans to scale up, document your import volumes per commodity each year. In the event of a customs audit, you will need to demonstrate that you correctly assessed your CBAM obligations and concluded you were below threshold.