Question 1

What is the CBAM 50-tonne threshold?

Accepted Answer

Under EU Reg 2025/2083 (Art. 1(2), the Omnibus amendment), an importer whose cumulative annual mass of CBAM goods — steel, aluminium, fertilisers, and cement combined — stays under 50 tonnes for the calendar year is exempt from CBAM obligations for that year.

Question 2

Is the 50-tonne threshold per CN code, or per sector?

Accepted Answer

Neither — it's a single aggregate across ALL CBAM goods combined (steel + aluminium + fertilisers + cement together), per importer, per calendar year. A common misreading treats it as per-product or per-sector; the real rule combines everything.

Question 3

Does hydrogen or electricity count toward the 50-tonne threshold?

Accepted Answer

No — both are explicitly excluded from the de minimis exemption. Any volume of hydrogen or electricity imports is in full CBAM scope regardless of mass; they also don't count toward your 50-tonne total for the other four sectors.

Question 4

What happens if I cross the threshold partway through the year?

Accepted Answer

Once your cumulative annual mass exceeds 50 tonnes, CBAM obligations apply to your ENTIRE year's imports — including the tonnes already imported while you were still under the threshold, not just the excess.

CBAM 50-tonne threshold calculator

Frequently asked questions

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