Answers / CBAM
The CBAM 50 Tonne Threshold: What Counts and What Does Not
How does the CBAM 50 tonne de minimis threshold work?
An importer is exempt for a calendar year while the net mass of the Annex I goods it imports in that year does not cumulatively exceed 50 tonnes (Article 2a(1) of Regulation (EU) 2023/956). Once it is exceeded, every tonne imported that year is in scope (Article 2a(2)).
What the Act Says
- Article 2a(1)
- Only goods listed in Annex I count, by net mass (Annex VII point 1), aggregated over all CN codes per importer per calendar year.
- Article 2a(4)
- Electricity and hydrogen are outside the threshold.
- Annex III
- Goods originating in Iceland, Liechtenstein, Norway or Switzerland are outside CBAM and do not count toward the 50 tonnes.
- Article 27(2)(b) and 25a(4)
- Splitting imports artificially to stay under the threshold is circumvention; the authority disregards non-genuine arrangements.
- 50 t exactly
- Fifty tonnes is not more than fifty tonnes: an importer at exactly 50 t is still under the threshold.
What to Do
- Add up the Annex I goods you import in the year, by CN heading and by origin.
- Leave out goods from Annex III countries and goods outside Annex I (finished transformers, motors, insulated cables).
- If you may cross 50 t during the year, apply for authorisation before the import that crosses it.
Calculator: CBAM 50 t threshold
Sources
- Regulation (EU) 2023/956 (CBAM), consolidated text (CELEX 32023R0956)
- Regulation (EU) 2025/2083 amending the CBAM Regulation (CELEX 32025R2083)
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