The CBAM 50-tonne threshold, explained for suppliers
Since 2026, EU importers bringing in 50 tonnes or less of CBAM goods a year are exempt. That sounds like good news for suppliers, but it rarely applies to the buyers who matter most.
Quick answer
EU importers bringing in 50 tonnes or less of CBAM goods a year, across all suppliers combined, are exempt from CBAM obligations. Electricity and hydrogen are excluded from the threshold. An importer that crosses 50 tonnes is in scope for the whole year, so most large buyers still need your data.
What the threshold is
CBAM's simplification regulation, adopted in 2025, introduced a single mass-based exemption. An importer whose total net imports of CBAM goods stay at 50 tonnes or less in a calendar year has no CBAM obligations for that year: no authorisation, no declaration and no certificates. It replaced the old exemption for consignments worth under €150. Electricity and hydrogen are excluded from the threshold.
Importers above the threshold must buy CBAM certificates to cover the embedded emissions of everything they import, and the number of certificates depends directly on the emissions data their suppliers provide.
Why it rarely helps suppliers
The Commission's estimate is that the threshold exempts about 90% of importers but still covers 99% of embedded emissions. In other words, it removes lots of small importers, not the large buyers who account for most trade. If you ship full containers of aluminium profiles or steel products to Europe, your buyer is almost certainly above 50 tonnes.
The threshold also counts all of an importer's CBAM goods together, not just what they buy from you. A buyer that takes only 10 tonnes from you may import hundreds of tonnes from other suppliers.
Crossing the threshold mid-year
An importer that goes over 50 tonnes during the year falls into scope for all its imports that year, not just the tonnes above the limit. Importing above the threshold without being an authorised CBAM declarant can lead to penalties. That's why many buyers ask suppliers for data even when they expect to stay small.
What this means for you
- Ask each EU buyer whether they're above or below the threshold. Don't assume.
- Small buyers may not need your data now, but they may cross the threshold later.
- Traders and distributors often import from many suppliers and are usually above the threshold.
- Prepare one data pack per installation and year, so you can answer quickly whoever asks.
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Send your requestFrequently asked questions
Is the 50-tonne threshold per supplier or per importer?
Per importer, across all the CBAM goods it imports in a calendar year from all suppliers combined.
What happens if an importer crosses 50 tonnes during the year?
All its imports for that year fall into scope, and it must have authorised CBAM declarant status. Importing above the threshold without authorisation can lead to penalties.
Does the threshold apply to electricity and hydrogen?
No. Electricity and hydrogen are excluded from the 50-tonne exemption.
Sources
- European Commission: CBAM definitive regime
- German Emissions Trading Authority (DEHSt): CBAM definitive regime from 2026
- EUR-Lex: summary of the CBAM Regulation (EU) 2023/956
This guide explains the rules in plain language. It isn't legal advice; see our disclaimer. Always check the current official texts and your buyer's instructions.