The European Commission has confirmed that the EU’s 50-tonne CBAM exemption continues to keep excluded embedded emissions below the 1% ceiling set by the regulation, preserving the current threshold for qualifying importers.
The Commission’s assessment, published on 30 September, found that imports covered by the exemption accounted for 0.87% of relevant embedded emissions. The calculation was based on data covering the period from 1 April 2025 to 31 March 2026.
The finding evaluates the existing exemption rather than introducing an expansion of goods excluded from the Carbon Border Adjustment Mechanism (CBAM). Its purpose is to assess whether the mass-based threshold continues to balance reduced administrative requirements for smaller importers with the need to retain broad emissions coverage.
Annual mass threshold applies across imports
The 50-tonne threshold applies to the cumulative net mass of relevant CBAM goods imported by an individual importer during a calendar year. It is not a 50-tonne emissions allowance and does not reset for individual shipments.
Electricity and hydrogen are excluded from the benefit of the mass-based exemption.
This makes ongoing monitoring of purchasing and customs data important for businesses approaching the threshold. Multiple relatively small consignments can accumulate into a significant annual volume even when no individual shipment is large.
Exceeding the threshold triggers broader obligations
Under the amended CBAM regulation, an importer that exceeds the applicable threshold brings the relevant year’s covered imports within the CBAM obligations. The mechanism does not apply only to the quantity exceeding 50 tonnes.
Importers therefore cannot wait until their final shipment of December to establish whether they remain below the threshold. Annual volumes need to be tracked throughout the calendar year.
The Commission’s review provides a policy-level assessment of the exemption’s overall impact. It does not determine whether an individual importer qualifies and does not replace an importer’s own calculation of its annual covered volumes.
Smaller importers retain the existing threshold
For smaller traders, the Commission’s 0.87% finding confirms that the existing exemption remains within the regulation’s 1% emissions ceiling.
The practical compliance issue remains the accumulation of annual import volumes. An importer that fails to monitor its total relevant mass can move from exemption status to obligations covering the relevant year’s imports once the threshold is exceeded.
