CBAM 50-Tonne De-Minimis Exemption: Are You Exempt? (2026 Definitive Period)

Short version. Since 20 October 2025, importers who bring less than 50 tonnes per calendar year of CBAM-scope iron & steel, aluminium, cement, or fertilisers into the EU are exempt from CBAM obligations: no declarant authorisation, no quarterly reports, no certificate surrender. The European Commission estimates this exempts about 90% of importers (~182,000 SMEs) while still capturing 99% of embedded emissions in scope. Electricity and hydrogen have no threshold — every shipment triggers full CBAM obligations.

What changed on 20 October 2025

Before the Omnibus simplification, CBAM applied a value-based de-minimis: shipments worth less than €150 per consignment were exempt. That was per consignment, not per importer per year. A small importer making lots of small shipments easily blew past the €150-per-consignment cap and faced full CBAM compliance for a few hundred kilograms of steel.

The Omnibus replaced that with a single mass-based threshold: Regulation (EU) 2025/2083(updated 20 Oct 2025), Article 1(1), inserts a new Article 2(3a) into the framework regulation:

“This Regulation shall not apply to a CBAM authorised declarant where the total quantity of CBAM goods of CN headings 25, 28, 31, 72, 73 and 76 imported per calendar year does not exceed a mass of 50 tonnes.”

That sentence — six CN headings, one annual mass, no value test — is the entire exemption. Note that CN 2716 (electricity) and CN 28041000 (hydrogen) are NOT in the list. The Commission's own announcement on this is at EU TAXUD: Officially published — Simplifications for the CBAM(updated 20 Oct 2025).

Who is exempt — and who isn't

The exemption is binary: either you are under 50 tonnes cumulative annual mass for the four eligible sectors, or you are not. There is no proportional reduction. The table below maps the rule per sector:

What “exempt” actually removes

If your annual cumulative CBAM-eligible mass is under 50 tonnes and stays there, the entire compliance pipeline disappears:

• No authorised CBAM declarant status required. You don't need to apply through the central EU CBAM Registry and you don't need a National Competent Authority (NCA) review.
• No quarterly transitional reports (those ended 31 Dec 2025 anyway) and no annual definitive declaration from 2027 onwards.
• No certificate purchase or surrender.The CBAM certificate price (€75.36/tCO₂e for Q1 2026) doesn't apply to you at all.
• No need for an Indirect Customs Representative specifically for CBAM (you may still need one for general customs reasons).

Run any CBAM cost calculation on a shipment under 50 tonnes and our calculator now shows an inline notice indicating you may be exempt — verify your annual cumulative volume before relying on it.

The catch nobody talks about

The 50-tonne threshold is cumulative annual mass, tracked at importer level (your EORI number). That sounds simple until you realise:

1. You don't know in January whether you'll cross 50 t in December.
2. If you cross mid-year, you owe full CBAM obligations retroactively for every shipment from 1 January.
3. The customs authority can inspect mass on entry — but the cumulative-annual cross-check happens at year-end. If you crossed in November, the bill arrives in February of the following year.

We dive into the operational edge cases in our follow-up post, The 50-Tonne CBAM Trap: How Mid-Year Crossover Catches Importers Off Guard. If you're anywhere near the threshold, the defensive move is to register as an authorised CBAM declarant anyway — see Should You Register as a CBAM Declarant Anyway? The 40-60-Tonne Borderline.

Why the EU made this change

The Commission framed the simplification as cutting administrative burden for SMEs while keeping environmental coverage. The official numbers:

• ~182,000 importers exempt by the new threshold — over 90% of all CBAM-touching importers
• But the exempt cohort accounts for only ~1% of total embedded emissions in scope
• The 99% of emissions from large importers stays in scope — same compliance regime as before

Source: EU TAXUD: Simplifications for the Carbon Border Adjustment Mechanism — official announcement(updated 20 Oct 2025).

For a deeper unpack of what changed and why, Council of the EU press release on the simplification(updated 29 Sept 2025) summarises the political compromise.

What you should do this week

Three simple steps:

1. Pull your 2026 import volumes year-to-date from your customs filings (per CN heading 25, 28, 31, 72, 73, 76). Sum across all consignments.
2. Project your full-year 2026 volumebased on YTD run-rate and your forward order book. If the projection is under 40 t, you're comfortably exempt. If 40–60 t, register defensively (next post).
3. Set a calendar alert at 40 t cumulative as your internal warning. If you hit 40 t, take action immediately — register, or start declining new orders that would push you over.

FAQ

Am I exempt from CBAM if I import less than 50 tonnes per year?

Yes — for the four mass-bearing CBAM sectors (iron & steel, aluminium, cement, fertilisers) you are exempt from declarant authorisation, reporting and certificate surrender if your CUMULATIVE annual net mass of imports stays under 50 tonnes. The exemption was introduced by Regulation (EU) 2025/2083 (the CBAM Omnibus), in force since 20 October 2025. Electricity and hydrogen have NO threshold — even 1 kWh / 1 kg triggers full obligations.

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

Per calendar year, cumulative across all your imports of CBAM-scope goods. A single 30-tonne shipment is fine; six 10-tonne shipments in the same year (60 t total) is over the threshold. The Commission tracks aggregated mass at importer level, not consignment level.

What happens if I cross 50 tonnes mid-year?

You fall into full CBAM obligations RETROACTIVELY for the entire calendar year. That means you owe a CBAM declaration covering every shipment from January onwards, plus surrender obligation. Importers in the 40-60 t range should register as authorised CBAM declarants defensively even if they expect to stay under the threshold.

Does the exemption apply to electricity and hydrogen?

No. Electricity (CN 27160000) and hydrogen (CN 28041000) are explicitly excluded from the 50-tonne threshold. Any quantity triggers the full CBAM obligations: declarant authorisation, quarterly reporting, and certificate surrender.

Where is the official text of the exemption?

Regulation (EU) 2025/2083 of the European Parliament and of the Council of 8 October 2025, amending Regulation (EU) 2023/956. Published in the Official Journal on 20 October 2025 and in force from that date. The Commission's official announcement is on the EU TAXUD website.