The CBAM 50-tonne mass threshold

Since 1 January 2026 a single number decides whether a company must meet CBAM obligations: 50 tonnes. Anyone importing less in a calendar year is exempt. Anyone above it must be an authorised CBAM declarant – for all imports of the year.

At a glance

The net mass of all CBAM goods per importer and calendar year counts, as stated in the customs declarations.
Once the threshold is exceeded, the obligations apply to the whole year – not just the quantity above 50 t.
Electricity and hydrogen do not count: authorisation is required for them from the first import.
The competent authority (in Germany: DEHSt) has 120 days to decide on the application – longer if it requests more information.

Quick test: how close are you to the threshold?

Enter the quantity since the start of the year – the traffic light calculates like CBAMfix Threshold Watch: status, projection and by when you should apply for authorisation.

Total of all CBAM goods of iron and steel, aluminium, cement and fertilisers according to customs declarations (net mass without packaging). Do not count electricity and hydrogen. Nothing is stored.

What counts towards the threshold?

The threshold is set out in Art. 2a of the CBAM Regulation, inserted by Regulation (EU) 2025/2083. It refers to the net mass – i.e. the weight without packaging – of all goods listed in Annex I that an importer brings into the EU in a calendar year. The acceptance date of the customs declaration is decisive.

The total across all sectors counts: 20 t of screws, 15 t of aluminium profiles and 18 t of cement add up to 53 t – the threshold is exceeded even though no single group reaches 50 t.

Cement, fertilisers, iron and steel, aluminium: count towards the threshold
Electricity and hydrogen: no threshold, authorisation always required
Scrap (CN 7204), aluminium waste (7602) and many ferro-alloys: not CBAM goods

What happens when you exceed it?

Anyone exceeding 50 t is subject to the full obligations for all CBAM imports of the calendar year: authorised CBAM declarant status, annual CBAM declaration and surrender of certificates. Without authorisation, no further CBAM goods may be imported.

Anyone who exceeds the 50-tonne threshold without authorisation faces a penalty of 3 to 5 times the EU ETS excess emissions penalty (EUR 100 per tonne, inflation-indexed) per certificate not surrendered; a milder rule applies up to 55 t.

Why acting early matters

You apply for authorisation to the competent authority (in Germany: DEHSt) in the CBAM registry. The authority has 120 days to decide (Art. 4 Implementing Regulation (EU) 2025/486); if it requests more information, the period is extended. Anyone who only notices that the threshold is being crossed when the goods are already on their way risks them getting stuck at the border. So count and project the quantity on an ongoing basis – and apply as soon as it is foreseeable that 50 t will be reached.

How CBAMfix helps

CBAMfix reads customs duty notices and customs declarations with AI, checks every CN code against Annex I and counts the net mass per calendar year. From the course so far, CBAMfix projects when the threshold is likely to be crossed and writes to you in good time before the authorisation deadline.

Frequently asked questions

Does the threshold apply per CN code or in total?

In total. The sum of the net mass of all CBAM goods of an importer in the calendar year counts, across all CN codes and sectors – except electricity and hydrogen.

Does gross or net weight count?

The net mass, i.e. the weight without packaging, as stated in the customs declaration.

What applies if I exceed the threshold in autumn?

Then the obligations apply retroactively to all CBAM imports of the entire calendar year, including the quantities from the months before.

Do I need to do anything if I stay below 50 tonnes?

A CBAM declaration is then not required. However, you must state the exemption in each customs declaration (Art. 2a(1)). You should also keep track of your imports so you can show that you stayed below the threshold – and react in time if the quantity rises.

Stay on top of the 50-tonne threshold

CBAMfix reads your import documents, checks every CN code against Annex I, keeps count and warns you in time before the authorisation deadline.

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