Does the 50-Tonne CBAM Exemption Apply to Your Exports?

By Ahmed Medhat · Published9 May 2026 · Updated 30 September 2026

Does the 50-Tonne CBAM Exemption Apply to Your Exports?

The Omnibus Regulation (EU) 2025/2083 introduced a threshold that exempts importers whose CBAM imports do not exceed 50 tonnes a year (it does not apply to electricity or hydrogen) — and it has conditions that every exporter needs to understand.

What the 50-tonne rule says

Under Article 2a(1) of Regulation (EU) 2023/956, inserted by Regulation (EU) 2025/2083, an EU importer is exempted from the obligations under the Regulation where the net mass of the goods they import in a calendar year does not cumulatively exceed 50 tonnes. The act is explicit about how that total is taken: the threshold "shall apply to the total net mass of goods under all CN codes aggregated per importer and per calendar year". One total, every CN code, per importer — there is no country dimension in it, and no per-sector split.

This means the test is not about you. It is about everything your EU buyer imports: your tonnes are added to every other CBAM good that buyer brings in that year, from every supplier and every country. Cross the threshold and Article 2a(2) applies the full obligation to all emissions embedded in all goods imported in that calendar year — the whole volume, retrospectively, not the excess.

The two goods the threshold does not cover

Article 2a(4) is one sentence: "This Article shall not apply to imports of electricity or hydrogen." The whole article, threshold included. For those two goods there is no exempt volume: the importer must hold the status of authorised CBAM declarant before the first import of the year, and must declare, and purchase and surrender CBAM certificates, whatever the tonnage.

The act gives its reason in recital (4) of Regulation (EU) 2025/2083: in the electricity and hydrogen sectors the quantity of imports, the trade patterns, the customs information and the emission intensities differ substantially from those in iron and steel, aluminium, fertilisers and cement, so putting them under a mass threshold would need complex adjustments that would not deliver the cut in administrative cost the threshold exists for. The threshold is built for four sectors and counts goods in those four: recital (3) says it should apply cumulatively to all goods in the sectors of iron and steel, aluminium, fertilisers and cement, and the methodology in Annex VII, point 2, sums over "the four sectors considered".

So a hydrogen producer, or an electricity supplier, reading about a small-volume exemption should read no further: it is not theirs. Our hydrogen and electricity sector pages both say so.

The figure can move

The 50 tonnes is the opening setting, not a fixed number. Under Article 2a(3), by 30 April each year the Commission works out, on the import data of the preceding twelve months, whether the threshold keeps the exempt share at no more than 1 % of the emissions embedded in the imported goods and processed products. Where the recomputed value, worked by the Annex VII, point 2 methodology and rounded to the nearest ten, deviates from the applicable threshold by more than 15 tonnes, the Commission amends it by delegated act, and the amended threshold applies from 1 January of the following year. Our tools read the threshold from one constant, so a change lands once.

The Commission published an assessment on 30 September 2026. For 1 April 2025 to 31 March 2026, it indicates that the 50-tonne threshold would exempt 0.87 % of embedded emissions, below the 1 % limit (CBAM De Minimis Threshold Assessment). The 50 tonnes in Annex VII, point 1 stays in force unless it is amended.

What crossing it sets in motion

Three consequences follow the act's own timing. An importer who expects to exceed the threshold applies for authorisation (Article 5(1b)); the guide to the year's dates shows why applying early matters. The quarterly duty to hold certificates is met by the end of the quarter following the one in which the threshold was exceeded (Article 22(2a)). And an importer who bought certificates expecting to exceed the threshold and then did not shall have all of them repurchased on request, the request being made by 31 October (Article 23(2), second subparagraph; the repurchase runs under Article 23(1)).

Equally important: the threshold is an annual aggregate, not a per-shipment limit. A buyer who receives three shipments of 20 tonnes each across the year, 60 tonnes in all, does not qualify even though each shipment on its own is below 50 tonnes.

How to check if your buyer qualifies

Your EU buyer needs to total their annual imports of CBAM goods across every CN code and every origin — not just yours. To help them assess this accurately, provide:

• Your CN code (the 8-digit product classification)
• Your country of origin
• Your expected annual delivery volumes

If their total across all CBAM goods stays at or below 50 tonnes for the calendar year, they may be exempt for that year and declare that exemption in the customs declaration. The threshold resets annually and must be re-evaluated each reporting year.

Why you should still prepare verified emissions data

Even if your buyer currently qualifies for de minimis, there are two reasons to prepare your verified specific embedded emissions (SEE) data now:

First, export volumes grow. If your buyer's imports cross 50 tonnes in any future year, CBAM obligations apply to the whole calendar year's imports, with only the quarter-end timing of Article 22(2a) to work in. Verified data takes time to prepare; starting now means you are ready when volumes grow.

Second, your buyer may have other suppliers. The single mass-based threshold, 50 tonnes of net mass, aggregates across every CBAM good that buyer imports, under all CN codes and from all origins — not just your shipments, and not just your country. Your buyer may already be above threshold without realising it.

The bottom line

The de minimis rule provides genuine relief for small-volume importers, and so for exporters whose only EU buyers are small. But it is the EU importer's obligation to assess and claim it — not the exporter's. Your role is to understand the rule, help your buyer assess their position, and be ready with verified data when volumes grow.

Use the DeCarbonPro Gap Analysis tool to see the default value for your goods and its 2026, 2027 and 2028 mark-ups.