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
| Question | Answer |
|---|---|
| Which goods | CN codes in Annex I: cement, iron and steel, aluminium, fertilisers (electricity and hydrogen always need authorisation) |
| Which mass | Net mass on the customs declaration |
| Period | Calendar year, cumulative |
| Per whom | Per importer (or indirect customs representative acting as declarant) |
| Returned goods | Those 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
- European Commission: CBAM Questions and Answers, last updated 15 October 2026 Source: taxation-customs.ec.europa.eu
- European Commission: Reminder, CBAM goes live on 1 January 2026 (23 December 2025) Source: taxation-customs.ec.europa.eu
- European Commission: Carbon Border Adjustment Mechanism Source: taxation-customs.ec.europa.eu
- European Commission: CBAM legislation and guidance Source: taxation-customs.ec.europa.eu