The CBAM 50-tonne exemption: are you out of scope?

Not every importer carries the CBAM obligation. The EU’s 2025 Omnibus simplification (Regulation (EU) 2025/2083) replaced the old per-consignment value test with a single de minimis threshold: import 50 tonnes or less of CBAM goods in a year, and the obligation — authorisation, declaration, certificates — does not apply to you.

The design goal was proportionality: the threshold is set so that at least 99% of embedded emissions stay in scope — the exemption is designed to cover no more than 1% of them, because a small number of large importers account for most of the tonnes. The 50-tonne figure itself sits in Annex VII and is reviewed by the Commission each year, so it can move.

How the test actually works

The details are where importers misjudge it:

• Cumulative, not per shipment. The 50 tonnes is your total net mass of covered goods across the calendar year — every consignment, every supplier, every covered CN code added together, per importer. Twelve monthly shipments of 5 tonnes is 60 tonnes: in scope.
• Mass, not value. The old €150-per-consignment logic is gone. A single dense pallet of steel parts can weigh more than you think; price tells you nothing.
• All covered goods count together — except electricity and hydrogen. Steel fittings from one supplier and aluminium profiles from another go into the same bucket.
• Electricity and hydrogen sit entirely outside this exemption. The de minimis article simply does not apply to them: import either and the obligation applies regardless of tonnage — and their mass never enters the 50-tonne bucket either.

Near the line? Measure, don’t assume

The dangerous position is 30–60 tonnes a year, because the threshold is crossed mid-year, cumulatively, while the goods keep arriving. Practical sequence:

1. Add up last year’s covered imports — net mass per line, from your customs declarations, across all covered CN codes.
2. Project this year honestly, including the one-off order that might tip you over.
3. If you might cross, apply for authorised declarant status before you do — clearance of covered goods depends on it, and the application is not instant.
4. Keep the evidence. Staying under the threshold is a claim about your data; be able to show the sum.

And crossing is retroactive for the year: under Article 2a of the amended CBAM Regulation, exceed the threshold and the obligation covers all covered goods you imported in that calendar year — not just the tonnes above the line. Claiming the exemption is an act, too, not a silence: it is declared in the customs declaration. How authorities police undercounting follows Commission implementation practice; confirm specifics with official guidance before relying on the exemption.

The quiet upside of being under

Exempt still means counted: you only know you’re under 50 tonnes by reading every customs line — which is the same discipline the obligation demands. Do it once and you have your answer either way.

Next: put your own tonnes into the free CBAM calculator, or see the deadlines that bite if you’re in scope.