The 50-tonne threshold

The Omnibus simplification introduced a de minimis threshold. Anyone importing no more than 50 tonnes of CBAM goods per year, cumulatively, falls outside the obligations. That takes a large share of smaller importers out of scope.

What the threshold means

An importer who stays at or below 50 tonnes of cumulative net mass per year falls out of the reporting obligation, the declarant status and the certificate cost. The exemption was introduced by the Omnibus Regulation (EU) 2025/2083, in force since October 2025. It removes a large share of companies from the mechanism. The great majority of embedded emissions stays in scope, because the largest importers carry most of the volume.

Cumulative means cumulative

The 50 tonnes count across all CBAM goods together, not per product group. Thirty tonnes of steel plus twenty-five tonnes of aluminium is fifty-five tonnes. Over the line. The number to watch is the cumulative net mass across the whole year, not the size of any single consignment.

The two exceptions

The threshold does not apply to hydrogen and electricity. These two are in scope regardless of quantity. A single tonne counts. If you import either, the de minimis relief is simply not available to you.

What you should do

Record your imports across the year. Watch the cumulative net mass, not the size of the single shipment. If the trend points above 50 tonnes, prepare the authorised declarant status in good time. The application is not granted overnight.

Information on the CBAM is given to the best of our knowledge, as of June 2026, without guarantee. Dynamic values such as certificate prices, default values and deadlines can change. The applicable legal acts and the competent authorities are decisive. This article is not legal, tax or customs advice.