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 2(3a) of Regulation (EU) 2025/2083, an EU importer does not need to comply with CBAM if their total imports of CBAM goods from a single non-EU country are below 50 tonnes net mass per calendar year. This threshold is assessed per importer, per country of origin, per year.

This means: if your EU buyer imports less than 50 tonnes of your goods per year — and those goods originate from your country — they may have no CBAM obligation for those imports.

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 calculate their total annual imports of each CBAM good from your country. 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 from your country stays below 50 tonnes for the calendar year, they may be exempt for that year. 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 may have multiple suppliers from your country. The 50-tonne threshold aggregates across all suppliers from the same origin country — not just your shipments. 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.