The CBAM 50-tonne threshold: what happens when you cross it (with a simulator)

Under the EU’s CBAM, an importer is exempt for a calendar year as long as the net mass of the steel, aluminium, fertiliser and cement goods it imports stays at or below 50 tonnes, counting all CN codes together. Once the year’s running total goes past 50 t, the importer is subject to all CBAM obligations for all emissions embedded in all goods imported that year, from the first tonne in January, not only the excess. For 2026 imports, that means a CBAM declaration and the surrender of certificates by 30 September 2027; certificates go on sale on 1 February 2027.

Simulate your year

With the example figures, which are invented, 57 t arrive over the year. The running total passes 90% (45 t) in October and 50 t in November. From that month, the obligations cover all 57 t, including the 46 t that came in before November. Nothing was due in January, but January still counts.

What the rule says

The threshold was introduced by Regulation (EU) 2025/2083, the CBAM simplification omnibus, which adds an Article 2a, “De minimis exemption”, and an Annex VII to Regulation (EU) 2023/956. It applies from 1 January 2026 (Article 36(2)(b)).

• The figure: Annex VII, point 1, sets the threshold “at 50 tonnes of net mass”.
• The exemption: an importer is exempt where the net mass imported in a calendar year “does not cumulatively exceed” the threshold. It applies “to the total net mass of goods under all CN codes aggregated per importer and per calendar year” (Article 2a(1)).
• The crossing: an importer that exceeds it within the year is subject to all obligations “in respect of all emissions embedded in all goods imported in that calendar year” (Article 2a(2)).
• The exclusions: the article “shall not apply to imports of electricity or hydrogen” (Article 2a(4)).

The Commission sums up the effect in its press release IP/25/1563: the threshold exempts 90% of companies while still covering about 99% of emissions in imported CBAM goods. In its report on the application of CBAM (COM(2025) 783, December 2025), it expects about 18,000 importers to be in scope from 2026 with the 50 t exemption. According to DG TAXUD (14 January 2026), by 7 January more than 12,000 operators had applied for authorisation and more than 4,100 had obtained authorised CBAM declarant status; since 1 January customs checks the authorisation, and monitors the 50 t threshold, before release for free circulation.

The 50 t is not set in stone. By 30 April each year the Commission checks whether the threshold exempts no more than 1% of embedded emissions; if the resulting value deviates by more than 15 t, it amends the threshold from the following 1 January (Article 2a(3)).

What counts towards the 50 t

• Everything together. Recital 3 is explicit: the threshold applies cumulatively to all goods in the iron and steel, aluminium, fertiliser and cement sectors. There is no threshold per sector or per product.
• Per importer. The importer is the person lodging the customs declaration in its own name and on its own behalf or, with an indirect customs representative, the person on whose behalf it is lodged (Article 3(15)). It is not counted per supplier or per shipment: if you buy from five mills, the five add up.
• Net mass. The threshold is measured in net mass of the goods (Annex VII).
• What does not count. Electricity and hydrogen are outside the threshold. Copper is not one of the CBAM sectors, so copper tube does not count towards the 50 t (inferred from the sector list).

If you also price these goods against the metal, the guide on how to build a metal-indexed price list explains the formula.

What changes when you cross

• Authorised declarant. Apart from the Article 2a exemption, customs “shall not allow the importation of goods by any person other than an authorised CBAM declarant” (Article 25(1)).
• The March deadline has passed. An importer that applied for authorisation by 31 March 2026 “may provisionally continue to import goods” until the competent authority decides (Article 17(7a)).
• Crossing without authorisation carries a penalty. An importer that is not an authorised declarant and exceeds the threshold is subject to the penalty in Article 26(2), calculated on all emissions embedded in its imports for the year. It can be reduced if the excess is no more than 10% of the threshold, that is up to 55 t, or if the importer kept importing provisionally and its application was refused (Article 26(2a)).
• The Commission monitors the threshold. It shares with national authorities a list of importers that exceed 90% of the threshold (Article 25a(1)). That is why the simulator marks 45 t.

The 2027 dates for 2026 imports

• 1 February 2027. Member States start selling CBAM certificates on a common central platform to authorised declarants (Article 20(1)).
• 30 September 2027. The first CBAM declaration (Article 6(1)) and the first surrender of certificates (Article 22(1)) are due, both for the year 2026.
• From 2027, every quarter. At the end of each quarter, a declarant must hold certificates for at least 50% of the emissions embedded in goods imported since the start of the year (Article 22(2)). An importer that crosses the threshold mid-year meets that obligation by the end of the quarter after the one in which it crossed (Article 22(2a)).

What each tonne imported from China costs in euros is a separate calculation, with default values and the certificate price; the guide on CBAM cost per tonne does it.

Four common misreadings

• “Only the tonnes above 50 count.” No: once you cross, every tonne of the year counts.
• “It is 50 t of steel and another 50 t of aluminium.” No: all CN codes are added together.
• “It is a limit per shipment.” No: it is per importer and per calendar year. One container can be a large share of the threshold, but what counts is the year’s total.
• “At exactly 50 t I am already in.” No: the rule says “does not exceed”. At 50 t you are still exempt; at 50.1 t you are not.

More guides on importing and selling metal goods are in the guides index.

How HeavyDeals tracks it

HeavyDeals adds up your net mass of CBAM goods for the calendar year from the purchase order, before the goods sail, and compares it with the 50 t threshold. If a line is missing data, such as its customs code, it warns you. When an order takes you close to the threshold, you know in time to sort out your declarant authorisation. The mill’s verified emissions travel with each order, so you don’t pay on the default value. It warns; it does not block orders. See how it works.

Every figure and rule was checked against the sources above, on the date shown next to each; last review of this guide: 11 October 2026. The examples use illustrative figures, not today’s quotes. This is not legal or tax advice. Written with the help of AI and reviewed by the HeavyDeals team.