Under 50 tonnes of CBAM goods? Prove it. Over? Get ready.
According to the European Commission's CBAM Q&A, since 1 January 2026 importers of CBAM goods other than electricity and hydrogen need no CBAM authorisation if they stay below the annual threshold of 50 tonnes net mass. Tonne Tally totals your CBAM goods from your customs data, gives you a written verdict for 2026 and a forecast for 2027, and, if you are over, prepares the steps to become an authorised CBAM declarant.
Updated
- Every import line checked against the CBAM goods list by CN code, totalled by net mass per calendar year
- A written verdict with the evidence, plus the right TARIC document code for your broker to use
- If you are over or close: authorisation file, supplier emissions data requests and the 2027 deadlines
Most small importers are exempt, but only if they can show it
CBAM covers imports of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, including finished steel and aluminium articles classified under the listed CN codes. Since the definitive regime started on 1 January 2026, the Commission's Q&A describes one annual threshold: 50 tonnes of net mass of CBAM goods per importer per calendar year.
Under it, you need no authorisation and have no declaration or certificates to buy. Over it, you are subject to all CBAM obligations: an annual declaration of embedded emissions and surrender of certificates, for the first time by 30 September 2027 for 2026 imports. The count is cumulative across all your CBAM goods and consignments, includes returned goods of non-EU origin, and uses the net mass on your customs declarations.
Many small importers have never added up their imports this way. Codes sit across brokers and invoices, and the TARIC code your broker uses tells customs whether you expect to stay under. A clear tally now costs far less than finding out in 2027.
- The European Commission's CBAM Questions and Answers (last updated 15 October 2026) say importers of CBAM goods other than hydrogen and electricity below the annual single mass-based threshold of 50 tonnes do not need an authorisation, while importers of hydrogen and electricity always do. Source: taxation-customs.ec.europa.eu
- The same Q&A says authorised declarants above the threshold must submit the annual CBAM declaration and surrender certificates by 30 September each year, first by 30 September 2027 for 2026 imports, and that certificate sales start on 1 February 2027. Source: taxation-customs.ec.europa.eu
- The Q&A explains that the net mass in customs declarations counts towards the threshold, that exceeding 50 tonnes in a calendar year brings all CBAM obligations, that returned goods of non-EU origin count, and that TARIC code Y137 is only for importers who do not expect to exceed 50 tonnes. Source: taxation-customs.ec.europa.eu
- In a 23 December 2025 reminder, the Commission said CBAM applies from 1 January 2026 and that applications for authorisation must be made before import and at the latest by 31 March 2026 for importers concerned, warning of disruption, delays or penalties for late applicants. Source: taxation-customs.ec.europa.eu
Without it
- Dubrink: CBAM software for importers and suppliers. Its pricing page lists a free Connect plan that works only with suppliers…
- Your customs broker: Your broker has the data and may act as your indirect customs representative. Ask whether they will total CBAM net…
- Adding it up yourself: Possible with a full list of import lines and the CBAM goods list. Our €49 check is for when the data sits in several…
With Tonne Tally
- Every import line checked against the CBAM goods list by CN code, totalled by net mass per calendar year
- A written verdict with the evidence, plus the right TARIC document code for your broker to use
- If you are over or close: authorisation file, supplier emissions data requests and the 2027 deadlines
- CN code matching
- Net mass tally per EORI
How it works
- 1
Send your import data
Your 2026 import lines from your broker, customs software or import declarations: CN code, net mass, date, origin and EORI. If you have it, last year's data too, for the forecast.
- 2
We match and total
Each line is matched to the CBAM goods list by CN code and totalled by net mass for the calendar year, per EORI, including returned goods of non-EU origin. Within 2 business days.
- 3
Written verdict
Under, close or over the 50 tonnes, with the lines behind it, a 2027 forecast from your order plans and the TARIC code instructions for your broker.
- 4
If you are over or close
We prepare the authorisation application file for your national competent authority, supplier requests for embedded emissions data and a 2026 declaration workbook. Within 7 business days. You or your representative submit.
Features
CN code matching
Your codes checked against the CBAM goods list, including finished metal articles that importers often miss, with the matching rule shown for each line.
Net mass tally per EORI
Cumulative net mass by calendar year across all CBAM goods and consignments, per importer EORI, as the threshold works per importer.
Written verdict and evidence
A short PDF you can keep on file or show a customer, auditor or customs, with the spreadsheet of lines behind it.
Broker instructions
Which TARIC document code to declare and when to switch: Y137 only while you do not expect to exceed, and the authorised declarant codes once you do.
Year-ahead forecast
From your purchase plans, the month in which you would cross 50 tonnes in 2027.
Declarant pack
For importers over the line: authorisation application checklist, supplier emissions data request in English and the 2026 declaration workbook ready for the CBAM Registry.
A look inside
What you get: the working view and the delivery report.
Illustration of the layout, built from this page's own feature list. It shows no real results.
Who it's for
Wholesalers and retailers of metal goods
Tools, fixings, furniture parts or kitchenware in steel or aluminium, imported from outside the EU in a few containers a year.
Manufacturers buying semi-finished metal
Sheet, tube, wire or profiles bought from non-EU mills, where tonnage adds up quickly.
Garden and agricultural suppliers
Fertilisers imported in bags or bulk, where a few deliveries can cross 50 tonnes.
Customs brokers with small clients
You file declarations for many small importers and want a clean tally per client.
Works with
- CBAM goods list by CN code (Annex I)
- Import declaration exports from customs software
- Broker reports in Excel or CSV
- TARIC document codes Y137 and Y128
- CBAM Registry declaration fields
- EU national competent authorities for CBAM
- PDF verdict and Excel workbook
Pricing
One-time prices in EUR, paid after we confirm scope. Prices cover one importer EORI; extra EORIs are quoted. We do not submit applications or declarations, buy certificates or act as your customs representative; you or your representative do. Founding customer pricing applies to early-access orders.
Orders are subject to the Tonne Tally terms.
Tally
€49 one-time
Small importers who expect to be under
- 2026 import lines matched to CBAM goods
- Net mass total per calendar year
- Written verdict with evidence
- TARIC code instructions for your broker
- Delivered within 2 business days
Check and forecast
€149 one-time
Importers near the line or growing
- Everything in Tally
- 2025 lines reviewed for comparison
- 2027 forecast from your order plans
- Monthly tally sheet for your team
- One re-check of new 2026 data before year end
- Call to walk through the result
Declarant pack
€490 one-time
Importers over 50 tonnes
- Everything in Check and forecast
- Authorisation application file for your authority
- Supplier emissions data requests
- 2026 declaration workbook for the CBAM Registry
- Deadline calendar to 30 September 2027
- Delivered within 7 business days
Compared with the alternatives
- Dubrink
- CBAM software for importers and suppliers. Its pricing page lists a free Connect plan that works only with suppliers holding a paid licence, Starter at €1,990 a year up to 1,000 tonnes and Premium at €2,990 a year (checked 7 November 2026). Built for ongoing reporting rather than a one-off threshold check.
- Your customs broker
- Your broker has the data and may act as your indirect customs representative. Ask whether they will total CBAM net mass for you, and at what price.
- Adding it up yourself
- Possible with a full list of import lines and the CBAM goods list. Our €49 check is for when the data sits in several places or you want a written verdict on file.
Your first week
The threshold verdict arrives within 2 business days of complete import data; a Declarant pack within 7 business days.
- Day 1: You send import lines; we confirm scope and EORIs.
- Day 2: Written verdict and broker code instructions.
- Day 3–4: Forecast and tally sheet, if in your plan.
- Day 5–7: Authorisation file, supplier requests and declaration workbook, if over.
Security and data
- We use import line data only: CN codes, net mass, dates, origins and EORI. No personal customer data.
- Files are stored in the EU, encrypted in transit and at rest, and shared only with the people you name.
- Supplier names and prices in your files are never shared with anyone else.
- Project files are deleted 90 days after delivery or on request.
Questions
Is the 50-tonne threshold per shipment or per year?
Per year. It is the net mass of all CBAM goods imported by the same importer in a calendar year, across all codes and consignments. Electricity and hydrogen are outside the threshold; their importers always need authorisation.
What happens if we go over 50 tonnes?
You become subject to all CBAM obligations for that year: being an authorised declarant, declaring embedded emissions and surrendering certificates, first by 30 September 2027 for 2026. The Commission said applications must be made before import; if you are close, talk to your national authority and your broker now.
Do we need to do anything if we are under?
No authorisation, declaration or certificates. Your broker should declare the correct TARIC document code, and you should be able to show your total. Our verdict gives you that record.
Which goods count?
Goods listed by CN code in Annex I of the CBAM Regulation, in cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Many finished steel and aluminium articles are included, so we check every code.
When are certificates sold and the first declaration due?
Certificate sales start on 1 February 2027. The first annual declaration and surrender of certificates are due by 30 September 2027 for 2026 imports, according to the Commission's Q&A.
Is this legal or customs advice?
No. Tonne Tally is a data tally and document preparation service, not legal or customs advice. Your national competent authority decides on authorisation; confirm your position with them or a customs adviser.
Know where you stand before 30 September 2027
Written CBAM threshold verdict from €49; full declarant pack for importers over 50 tonnes at €490, paid once.
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