The European Commission has confirmed that the current 50-tonne CBAM exemption remains consistent with the mechanism’s emissions threshold, providing a current reference point for smaller importers while discussions continue over possible changes to aluminium coverage.
The Commission’s assessment, published on September 30, found that the existing threshold would have excluded 0.87% of embedded emissions during the period from April 1, 2025 to March 31, 2026. The result remains below the 1% maximum exemption level established under the CBAM Regulation.
The annual review determines whether the mass-based exemption continues to meet the environmental limit set by the legislation. Under the applicable rules, the threshold is adjusted if the calculated level differs from the existing threshold by more than 15 tonnes.
Current threshold remains relevant for importer obligations
Importers whose volumes exceed the applicable single mass threshold must apply for authorised-declarant status, according to the Commission’s guidance for the definitive CBAM regime.
The latest assessment therefore gives smaller businesses a clearer basis for determining when the additional administrative requirements associated with authorised status become relevant under the current framework.
The assessment does not, however, change the separate policy discussion surrounding aluminium. The proposed five-tonne threshold for aluminium has not been enacted and remains part of ongoing CBAM reform negotiations.
Aluminium reform remains separate from annual threshold review
The Commission’s statistical assessment and the broader debate over aluminium address different policy questions.
The annual review tests whether the mass exemption remains within the scheme-wide 1% embedded-emissions limit. At the same time, producers and other market participants can raise separate concerns about the competitive effects of applying a particular threshold to higher-value aluminium products.
Meeting the environmental test for the exemption therefore does not resolve the wider discussion over how aluminium should be treated under a reformed CBAM framework.
For smaller distributors, the 50-tonne threshold provides a clearer basis for current compliance planning. Companies whose import volumes are increasing still need to monitor those volumes, since crossing the applicable threshold can result in a different compliance workload from that anticipated when supply contracts were originally agreed.
