CBAM: does the 50-tonne exemption apply to me?

Short answer: If you import less than 50 tonnes of CBAM goods per calendar year, the Omnibus simplification exempts you from the core obligations. Cross that threshold and you fall fully within the regime.

What is the 50-tonne threshold?

The Carbon Border Adjustment Mechanism (CBAM), set out in Regulation (EU) 2023/956, has applied in its definitive form since 1 January 2026. The mechanism prices the embedded CO2 emissions of imported goods at the EU's external border.

Under the Omnibus simplification a de-minimis threshold applies: importers who bring in less than 50 tonnes of CBAM goods per year are exempt. The threshold is designed to spare small importers and concentrate the administrative burden on the parties that import the bulk of the volumes covered by CBAM.

Which goods count?

CBAM applies to a defined list of goods groups: iron and steel, aluminium, cement, fertiliser, electricity and hydrogen. Only imports within these categories count towards the 50-tonne calculation. If you import only products outside this list, CBAM does not affect you.

To determine the threshold, add up your total annual import of CBAM goods. What matters is the physical tonnage you bring across the EU's external border, not the value.

What if I am above it?

If you exceed 50 tonnes, you must apply for 'authorised CBAM declarant' status. The application must be submitted by 31 March 2026 at the latest. You then buy CBAM certificates for the embedded CO2 of your imports and file your first annual declaration before 30 September 2027. To do so you request emissions data from your suppliers; start early, as this data is often not readily available.

Unsure whether you sit below or above the threshold? Calculate your annual volume per goods group and keep a margin, because crossing the line activates the full set of obligations.

Read the main file: CBAM carbon border charge on imports. Or take the Transport & Logistics scan.