Do the new CBAM rules apply to you? The 50-tonne threshold explained

The EU Carbon Border Adjustment Mechanism entered its definitive phase on 1 January 2026. The two-year reporting-only period is over, and for the first time the mechanism carries real financial consequences. The first question for any business that buys goods from outside the EU is a simple one. Do these rules actually apply to me?

The 50-tonne de minimis

The simplification package that took effect in October 2025 replaced the old exemption, which was based on a consignment value of 150 euros, with a clearer mass-based test. If your total annual net imports of CBAM goods stay below 50 tonnes, you are fully outside the mechanism. That means no reporting, no authorisation and no certificates. The threshold is assessed across the calendar year, not per shipment, so it is the running total that matters.

The goods in scope are cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. One important point of detail: the 50-tonne relief applies to the mass-based goods. Imports of electricity and hydrogen are covered regardless of volume.

If you are above the threshold

Businesses that cross 50 tonnes must hold authorised CBAM declarant status to keep importing in-scope goods for free circulation. Applications are made through your national competent authority, and the route to authorisation opened ahead of the 31 March 2026 application point. From that status flow the substantive duties: collecting embedded-emissions data, filing an annual declaration and surrendering certificates.

The timeline is more forgiving than many expect. Certificate purchasing begins in February 2027, and the first declaration and certificate surrender, covering imports made during 2026, falls due on 30 September 2027. The work of gathering supplier data, however, is best started well before then.

What to do next

Most businesses fall clearly on one side of the line or the other, but borderline importers and those buying small quantities across several suppliers should total their annual volumes carefully. Getting the in-scope assessment right is the foundation for everything that follows, and it is the first thing our CBAM-training stage is designed to help you settle.

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