The CBAM 50-tonne threshold: how the de-minimis exemption works

What is the 50-tonne de-minimis threshold?

The de-minimis threshold is a size cut-off in the CBAM rules. Regulation (EU) 2025/2083 amended the CBAM Regulation so that an importer whose imports of CBAM goods do not exceed 50 tonnes of cumulative net mass per calendar year is treated as outside the main CBAM obligations for that year (Regulation (EU) 2023/956, Article 2a, as amended).

The threshold is designed to keep smaller, occasional importers out of the full obligation set while still capturing the bulk of embedded emissions, which sit with high-volume importers.

It is cumulative, not per shipment

The 50 tonnes is a running total of net mass across the calendar year for a single legal entity — not a per-shipment or per-consignment figure. Several small imports that each look trivial can still add up to more than 50 tonnes over the year.

Because the measure is cumulative net mass per legal entity, structure matters: two companies in the same group are counted separately, while a single company's imports across different suppliers and customs entries are counted together.

Electricity and hydrogen are excluded from the exemption

The de-minimis exemption does not apply to electricity or hydrogen. Importers of those goods are not taken outside the obligations by staying under 50 tonnes (Regulation (EU) 2023/956, Article 2a(4), as amended by Regulation (EU) 2025/2083).

For the other CBAM sectors — cement, iron and steel, aluminium, and fertilisers — the cumulative-net-mass test is what decides whether the threshold could be relevant.

Why CN scope matters before the threshold math

The 50-tonne count only includes goods that are actually in CBAM scope. Whether a product is in scope depends on the CN code it is declared under, listed in Annex I of Regulation (EU) 2023/956 — not on how the product is described commercially.

So the practical order is: first check which of your imported goods are CBAM goods by CN code, then add up their cumulative net mass for the year. Adding up mass before confirming scope can over- or under-count.

What happens if the running total crosses 50 tonnes?

Article 2a(2) provides that where an importer exceeds the single mass-based threshold within the relevant year, the importer is subject to the Regulation's obligations in respect of all emissions embedded in all goods imported in that calendar year. The rule does not apply only to the tonnes above the threshold.

Regulation (EU) 2025/2083 also states that an importer expecting to exceed the annual threshold should obtain authorised CBAM declarant status before the single mass-based threshold is exceeded. A preparation workflow should therefore flag the forecast before the crossing import rather than waiting for a year-end total.

CBAM Pulse can keep the running record and forecast visible, but it does not decide authorisation status, penalties, declaration scope, or the action required for a particular importer. Route those questions to the national competent authority or a qualified adviser.

Keep a running annual mass record

A useful running annual mass record keeps the importing legal entity, customs entry date and reference, declared CN code, scope-check state, covered sector, net mass, and running covered-goods total on the same row. Keep the source document and any unresolved classification question linked to that row.

Reconcile the record through the year and compare both the confirmed total and expected remaining imports with the threshold. Do not treat a missing customs entry, an unresolved CN code, or an unavailable net-mass field as zero merely to keep the running total below the threshold.

How to check where you stand

These free tools can help you work through it, but they are informational and do not decide your obligations — verify anything that matters with your national competent authority or a qualified adviser.

• Check whether a specific CN code is a CBAM good with the goods checker.
• See how the 50-tonne cumulative test could apply to your yearly volume with the threshold checker.
• Work through the wider set of preparation steps with the readiness checklist.