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Check whether the 50-tonne de minimis exemption applies to your EU buyer. The threshold counts the total net mass of goods under all CN codes, aggregated per importer per calendar year (Reg (EU) 2023/956, Art. 2a(1)) — so list every CBAM good that buyer imports, and the answer is the sum.
List every CBAM good this EU buyer imports in the calendar year. The threshold is one total across all of them.
Regulation (EU) 2025/2083 inserted Article 2a into Regulation (EU) 2023/956, introducing a single mass-based threshold of 50 tonnes net mass per calendar year. An importer whose imported CBAM goods do not cumulatively exceed it is exempted from the obligations under the Regulation, and declares that exemption in the customs declaration.
The threshold applies to the total net mass of goods under all CN codes, aggregated per importer and per calendar year. It is one figure, not one per sector: an EU buyer importing 30 tonnes of steel and 30 tonnes of cement has imported 60 tonnes of CBAM goods and is over the threshold, even though neither line reaches 50 tonnes on its own. Article 2a contains no country dimension either — where the goods came from does not enter the test.
Crossing the threshold is not a charge on the excess. Article 2a(2) makes the importer subject to all obligations in respect of all emissions embedded in all goods imported in that calendar year — the exemption is lost for the whole year, retrospectively.
The threshold is assessed per EU importer — not per exporter, not per consignment, and not per country of origin.
Hydrogen and electricity are excluded from the de minimis threshold by Article 2a(4). Their tonnes are not counted towards it, and they carry full CBAM obligations regardless of volume.
Source: Reg (EU) 2023/956 Art. 2a and Annex VII point 1, both inserted by Reg (EU) 2025/2083. Not legal or compliance advice.
Article 2a and Annex VII were both inserted into Reg (EU) 2023/956 by Reg (EU) 2025/2083.
Calculate your exact certificate obligation using the sector calculator.
Sector Calculator →The de minimis threshold applies to your EU buyer's annual imports — not to your production volume or total exports. A single exporter selling to five EU buyers each receiving 40 tonnes may leave every one of those buyers under the threshold even though total export volume is 200 tonnes. It works the other way too: your 40 tonnes can put a buyer over it, if that buyer already imports CBAM goods from somebody else.
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