The European Commission will retain the 50-tonne annual CBAM threshold for smaller importers after a review found that goods excluded under the threshold represented less than the emissions ceiling set for the mechanism.
The Commission published its assessment on 30 September, covering imports made between 1 April 2025 and 31 March 2026. Goods below the threshold represented 0.87% of embedded emissions, remaining within the 1% maximum share established to protect the environmental coverage of the Carbon Border Adjustment Mechanism.
The decision preserves the existing treatment for smaller importers rather than introducing a new exemption. For businesses such as smaller steel distributors and industrial buyers, the principal change is continued application of the existing threshold.
Annual volumes determine CBAM threshold status
The 50-tonne limit is calculated cumulatively over the calendar year for an importer across the relevant mass-based CBAM sectors. It is not assessed independently for each shipment or individual supplier.
This makes consolidated import records important for companies purchasing covered products through multiple channels. Businesses with separate purchasing teams for steel, aluminium and other covered goods need to establish the combined volume attributed to the same importing entity.
An importer purchasing 30 tonnes of covered steel and another 25 tonnes of a different relevant covered material would exceed the threshold. Using different suppliers for those purchases would not alter the aggregate volume attributed to the importer.
Electricity and hydrogen remain outside the mass-based exemption
The mass-based threshold does not apply to electricity and hydrogen. Where an importer exceeds the applicable threshold, the relevant obligations apply to its annual imports rather than only to the quantities above 50 tonnes.
For companies operating close to the limit, this distinction makes cumulative purchasing volumes the key compliance metric. The quantity in the latest delivery does not determine whether the threshold has been exceeded.
The Commission’s review maintains the current position for genuinely small importers while leaving businesses close to the threshold responsible for monitoring their total annual covered tonnage.
