Understanding the CBAM 50-Tonne Exemption (2026-2027)

The EU Carbon Border Adjustment Mechanism (CBAM) is coming into full effect in 2026, and many small-scale importers are asking: "Do I need to comply?"

Good news: If you import less than 50 tonnes of CBAM-covered goods per year, you're exempt from CBAM reporting and payments.

What is CBAM?

CBAM is the EU's carbon tariff on imports of carbon-intensive goods. It aims to prevent "carbon leakage" (moving production to countries with weaker climate rules) by charging importers for the carbon emissions embedded in their products.

Timeline

• 2023–2025: Transition period (quarterly reporting, no payments)
• 2026–2027: Full enforcement (small-importer exemption applies)
• 2028+: Exemption may be removed (review pending)

Which Goods Are Covered?

Starting in 2026, CBAM applies to:

1. Iron and steel (HS codes 72, 73)
2. Aluminum (HS codes 76)
3. Cement (HS codes 2507, 2523)
4. Fertilizers (HS codes 31)
5. Electricity (cross-border)
6. Hydrogen (HS code 2804)

Expected expansion by 2028: Plastics, chemicals, organic chemicals.

The 50-Tonne Exemption: How It Works

If you import less than 50 tonnes of CBAM goods (measured by gross mass) in a calendar year, you are fully exempt from:

• ✅ CBAM certificate purchases
• ✅ Quarterly declarations
• ✅ Authorized CBAM declarant registration

Example Scenarios

Important: The 50-tonne threshold is cumulative across all CBAM goods, not per product category.

How to Calculate Your Tonnage

Step 1: Identify CBAM-Covered Products

Check your import invoices for HS codes matching CBAM goods (iron, steel, aluminum, cement, fertilizers).

Step 2: Sum Gross Mass

Add up the gross mass (not net weight) of all CBAM goods imported in the calendar year.

Example:
- Jan–Mar: 12 tonnes steel (HS 7208)
- Apr–Jun: 8 tonnes aluminum (HS 7606)
- Jul–Sep: 15 tonnes cement (HS 2523)
- Oct–Dec: 10 tonnes steel (HS 7210)
Total: 45 tonnes → ✅ EXEMPT

Step 3: Monitor Threshold

If you approach 50 tonnes mid-year, consider:

• Delaying shipments to next year
• Registering as CBAM declarant proactively

What If You Exceed 50 Tonnes?

Once you pass the threshold, you must:

1. Register as an authorized CBAM declarant (via EU member state customs)
2. Purchase CBAM certificates (based on embedded emissions)
3. File quarterly declarations (due 1 month after quarter end)
4. Surrender certificates annually (by May 31 of following year)

How CBAM Certificates Work

• Price is based on EU ETS carbon price (currently ~€65/tonne CO₂)
• You must prove the carbon intensity of your goods (or use default values)
• Certificates can be bought/sold on the CBAM registry

Example cost calculation:

80 tonnes of steel imported
× 1.8 tonnes CO₂ per tonne steel (default value)
= 144 tonnes CO₂
× €65/tonne CO₂
= €9,360 CBAM cost

How to Claim the Exemption

You don't need to "claim" it actively. If you stay under 50 tonnes:

• ✅ No registration required
• ✅ No declarations required
• ✅ No certificates required

However, you should keep records proving you're under the threshold (invoices, customs declarations, weight certificates) in case of an audit.

Will the Exemption Continue After 2027?

The European Commission will review the small-importer exemption by end of 2027. Possible outcomes:

• Keep the 50-tonne threshold (most likely)
• Lower the threshold (e.g., to 25 tonnes)
• Remove the exemption entirely (less likely)

If you're a growing business, plan for the possibility of CBAM compliance starting in 2028.

Check Your CBAM Status Now

Use our CBAM Readiness Checker to:

• ✅ See if you qualify for the exemption
• ✅ Estimate CBAM costs if you exceed the threshold
• ✅ Get a supplier questionnaire to gather emissions data

Next steps:

• Confirm scope in CBAM overview
• Store supplier data via the Readiness Wizard
• Align packaging/footers with France & Germany packaging

Run CBAM Check →

Last updated: October 2025 Source: EU CBAM Regulation 2023/956, European Commission CBAM FAQ