The European Commission has found that the existing 50-tonne CBAM threshold remains below the emissions limit set by the Carbon Border Adjustment Mechanism, reducing immediate uncertainty for smaller importers.
The assessment, published on 30 September, calculated that the threshold would exclude 0.87% of embedded emissions, below the 1% ceiling established under the regulation.
The review does not introduce a new exemption. Instead, it assesses the existing mass-based threshold against the emissions limit applicable under CBAM.
Assessment covers March 2025 to April 2026
The Commission based its calculation on the period from 1 April 2025 to 31 March 2026. Under the CBAM regulation, the Commission is required to assess the threshold against the relevant emissions limit.
Where the calculated threshold differs from the applicable level by more than 15 tonnes, the regulation requires the Commission to amend the threshold through delegated legislation.
The latest finding therefore concerns the operation of the existing threshold rather than establishing a new mass limit. It also does not create a blanket exemption covering every sector within CBAM.
Import volumes remain relevant for businesses near the threshold
For companies operating close to the 50-tonne threshold, the volume of covered goods imported remains relevant to commercial planning. Procurement teams need to monitor covered goods consistently rather than treating individual small shipments as the basis for determining eligibility.
The assessment provides greater planning certainty for smaller import flows while retaining the distinction between administrative relief and the broader scope of CBAM.
Most embedded emissions remain within CBAM
The 0.87% emissions share excluded by the threshold leaves the overwhelming majority of embedded emissions within the mechanism.
For larger importers, the assessment does not remove the requirements associated with emissions data and CBAM certificates. Those requirements continue to influence supplier assessment and procurement decisions for covered imports.
