Does the 50-Tonne CBAM Exemption Apply to Your Exports?

Does the 50-Tonne CBAM Exemption Apply to Your Exports?

Most exporters assume CBAM applies to every shipment they send to the EU. The Omnibus Regulation (EU) 2025/2083 introduced a threshold that exempts many small shipments — but it has strict conditions that every exporter needs to understand.

What the 50-tonne rule says

Under Article 2a(1) of Regulation (EU) 2023/956, inserted by Regulation (EU) 2025/2083, an EU importer is exempted from the obligations under the Regulation where the net mass of the goods they import in a calendar year does not cumulatively exceed 50 tonnes. The act is explicit about how that total is taken: the threshold "shall apply to the total net mass of goods under all CN codes aggregated per importer and per calendar year". One total, every CN code, per importer — there is no country dimension in it, and no per-sector split.

This means the test is not about you. It is about everything your EU buyer imports: your tonnes are added to every other CBAM good that buyer brings in that year, from every supplier and every country. Cross the threshold and Article 2a(2) applies the full obligation to all emissions embedded in all goods imported in that calendar year — the whole volume, retrospectively, not the excess.

What the exemption does NOT cover

Two sectors are explicitly excluded from the de minimis threshold regardless of volume: hydrogen and electricity. Exporters of hydrogen must comply with CBAM regardless of quantity.

Equally important: the 50-tonne threshold is an annual aggregate — not a per-shipment limit. A buyer who receives three shipments of 20 tonnes each across the year (total 60 tonnes) does not qualify for exemption even though each individual shipment is below 50 tonnes.

How to check if your buyer qualifies

Your EU buyer needs to total their annual imports of CBAM goods across every CN code and every origin — not just yours. To help them assess this accurately, provide:

• Your CN code (the 8-digit product classification)
• Your country of origin
• Your expected annual delivery volumes

If their total across all CBAM goods stays at or below 50 tonnes for the calendar year, they may be exempt for that year and declare that exemption in the customs declaration. The threshold resets annually and must be re-evaluated each reporting year.

Why you should still prepare verified emissions data

Even if your buyer currently qualifies for de minimis, there are three strong reasons to prepare your verified specific embedded emissions (SEE) data now:

First, export volumes grow. If your buyer's imports cross 50 tonnes in any future year, CBAM obligations apply immediately — with no grace period. Verified data takes time to prepare; starting now means you are ready when volumes grow.

Second, your buyer almost certainly has other suppliers. The 50-tonne threshold aggregates across every CBAM good that buyer imports, under all CN codes and from all origins — not just your shipments, and not just your country. Your buyer may already be above threshold without realising it.

Third, EU buyers increasingly require carbon transparency data from their entire supply chain — not just for CBAM compliance but for their own ESG reporting. Verified SEE data positions you as a preferred supplier regardless of the threshold.

The bottom line

The de minimis rule provides genuine relief for small-volume exporters. But it is the EU importer's obligation to assess and claim it — not the exporter's. Your role is to understand the rule, help your buyer assess their position, and be ready with verified data when volumes grow.

Use the DeCarbonPro Gap Analysis tool to model your CBAM exposure at different export volumes and understand your threshold position.