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Check whether the 50-tonne de minimis exemption applies to your EU buyer. Includes multi-product and multi-importer analysis — the nuances cbamguide misses.
Regulation (EU) 2025/2083 introduced a single mass-based threshold of 50 tonnes net mass per year for EU importers. Importers whose annual imports of CBAM goods from a single non-EU country fall below this threshold are exempt from purchasing CBAM certificates for those goods.
The threshold applies per EU importer — not per exporter, not per consignment, and not combined across sectors. An EU buyer importing 30 tonnes of steel and 30 tonnes of cement is below threshold in both sectors individually, even though their total CBAM goods import is 60 tonnes.
Hydrogen and electricity are excluded from the de minimis threshold. All hydrogen and electricity imports are subject to full CBAM obligations regardless of volume.
Source: Reg (EU) 2025/2083 Annex VII · Art.2a of Reg (EU) 2023/956 as amended. Not legal or compliance advice.
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 is fully compliant at the buyer level even though total export volume is 200 tonnes.