A common misreading treats this as a per-product limit. It isn't — it's a single aggregate across your whole CBAM import portfolio, with two sectors excluded outright.
Last verified: 02 September 2026
Common misreading: treating this as a per-product or per-CN-code limit. It's a single aggregate across your whole CBAM import portfolio — get this wrong and you can significantly underestimate whether you're actually in scope.
EU Regulation 2025/2083 (Art. 1(2), the Omnibus amendment) sets the de minimis relief at 50 tonnes of cumulative net mass per calendar year — but critically, that 50 tonnes is a single combined total across all four covered sectors together: iron & steel, aluminium, fertilisers, and cement. It is not 50 tonnes per sector, and not 50 tonnes per CN code.
A company importing 20 tonnes of steel and 35 tonnes of aluminium in the same year has a combined total of 55 tonnes — over the threshold — even though neither individual sector alone would trigger it.
Two of the six CBAM sectors sit outside this relief altogether. Hydrogen and electricity imports are in full CBAM scope regardless of volume — a single shipment triggers obligations. They also don't count toward, or benefit from, the 50-tonne aggregate that applies to the other four sectors.
If your cumulative mass across the four aggregated sectors reaches or exceeds 50 tonnes at any point in the calendar year, CBAM obligations apply to your entire year's imports in those sectors — including the tonnes imported earlier in the year while you were still under the threshold, not just the amount that pushed you over.
Since the rule is a combined aggregate rather than a per-product check, the useful question is your total mass across all four sectors so far this year — not any one shipment or CN code in isolation.
Check your own cumulative position with the 50-tonne threshold calculator.
Neither. It's a single aggregate across ALL CBAM goods combined — steel, aluminium, fertilisers, and cement together — per importer, per calendar year. This is the single most common misreading of the rule.