Guide · EU CBAM

CBAM 50-tonne threshold: how it works

Updated · Rotomal

Since 1 January 2026, an EU importer of CBAM goods other than electricity and hydrogen needs no CBAM authorisation, declaration or certificates if the net mass of all its CBAM goods does not exceed the 50-tonne annual threshold, according to the Commission's Q&A. The count is cumulative across all codes and consignments and uses the net mass on customs declarations. If you exceed it, all CBAM obligations apply, with the first annual declaration and certificate surrender due by 30 September 2027 for 2026 imports.

What counts

QuestionAnswer
Which goodsCN codes in Annex I: cement, iron and steel, aluminium, fertilisers (electricity and hydrogen always need authorisation)
Which massNet mass on the customs declaration
PeriodCalendar year, cumulative
Per whomPer importer (or indirect customs representative acting as declarant)
Returned goodsThose of non-EU origin count towards the threshold

Key dates

  • 1 January 2026: definitive CBAM regime and the 50-tonne threshold apply.
  • 31 March 2026: the Commission's stated latest date for authorisation applications by importers concerned.
  • 1 February 2027: sale of CBAM certificates starts.
  • 30 September 2027: first annual declaration and certificate surrender, for 2026 imports.

What to do

  • Pull every 2026 import line with CN code and net mass.
  • Match codes to Annex I and total the net mass per importer EORI.
  • If clearly under: keep the tally on file and make sure your broker uses Y137 only while you do not expect to exceed.
  • If close or over: contact your national competent authority about authorisation and ask suppliers for embedded emissions data.

If you want it checked for you

Tonne Tally totals your CBAM goods and gives you a written verdict from €49, with a declarant pack at €490 if you are over, paid once.

Questions

Where is the 50-tonne threshold described?

In the European Commission's CBAM Questions and Answers, last updated 15 October 2026, which describe a single annual mass-based threshold of 50 tonnes. For the exact legal provision, check the CBAM Regulation on EUR-Lex or ask your national competent authority.

Can a customs representative carry the obligations?

Yes. An indirect customs representative can act as authorised CBAM declarant for several importers and submits one annual declaration covering all their CBAM goods.

Sources