The European Commission has found that the EU’s 50-tonne CBAM exemption excludes 0.87% of covered embedded emissions, remaining below the 1% emissions ceiling established for the mechanism.
The assessment, published on 30 September, examined imports recorded between 1 April 2025 and 31 March 2026. The review assessed the existing mass-based threshold rather than establishing a new exemption.
Commission assessment applies the existing threshold
Under the Carbon Border Adjustment Mechanism, the European Commission is required to assess the emissions covered by the single mass-based threshold. The review therefore considers the amount of embedded emissions excluded when imports remain within the applicable 50-tonne limit.
The legislation also contains a separate adjustment mechanism. Where the threshold calculated under the prescribed methodology differs from the applicable threshold by more than 15 tonnes, the Commission is required to adopt a delegated act.
The latest assessment found that the existing threshold remains within the emissions limit, with the excluded 0.87% of covered embedded emissions below the mechanism’s 1% ceiling.
Annual import volume determines exemption status
The 50-tonne threshold is applied to an importer’s cumulative annual volume of relevant CBAM-covered goods, rather than being assessed separately for each shipment.
Electricity and hydrogen are excluded from the mass-based exemption. Companies importing other covered goods must therefore monitor their combined annual quantities to determine whether they remain below the applicable threshold.
Crossing the threshold has consequences for the relevant year’s imports. Once the limit is exceeded, the covered imports for that year become subject to the CBAM obligation, rather than only the quantity above 50 tonnes being brought into the mechanism.
The Commission’s review keeps the exemption within its prescribed emissions coverage while leaving companies responsible for tracking cumulative annual imports and identifying when their CBAM status changes.
