CBAM 50-tonne threshold and the 2027 timeline
The 50-tonne threshold looks at an EU importer's total CBAM goods in a year – not at how much one factory sells.
Key points
- Importers with no more than 50 t of CBAM goods per year are exempt (Regulation (EU) 2025/2083).
- Importers above 50 t must apply for authorised CBAM declarant status.
- 2026 imports: certificates bought from February 2027; declaration and surrender by 30 September 2027.
- For suppliers: large customers are almost certainly in scope; small ones may be exempt.
1. How the threshold works
The simplification Regulation (EU) 2025/2083, published in October 2025, introduced a single mass-based threshold: companies importing less than 50 tonnes of CBAM goods a year are exempt from CBAM obligations. The Commission expects this to exempt about 182,000 importers, mostly SMEs and individuals, while still covering over 99% of in-scope emissions.
- Per importer: all CBAM goods from all suppliers and codes added together.
- Per calendar year.
- Above 50 t: the Commission's definitive-regime page says importers (or their indirect customs representatives) above the threshold must apply for authorised CBAM declarant status.
Example: a German distributor buying 30 t of bolts from you and 25 t of steel brackets elsewhere has 55 t – above the threshold.
2. What it means for suppliers
- Large distributors and buyers are far above 50 t and are likely to ask for emissions data, or negotiate on the default-value cost.
- Small or sample customers may be exempt, but only their annual total decides – ask them.
- Either way, data in a format the declarant can use directly saves a scramble later.
3. Timeline
| When | What | Source |
|---|---|---|
| 1 Jan 2026 | Definitive regime starts; importers incur certificate obligations for 2026 imports | Commission definitive-regime page |
| First week after each 2026 quarter | Quarterly certificate price published (Q1 €75.36, Q2 €75.28, Q3 €82.32) | Commission price page |
| 4 Jan 2027 | Q4 2026 price published | Commission price page |
| From Feb 2027 | Certificates bought on the common central platform; weekly prices from 2027 | Commission price page |
| By 30 Sep 2027 | 2026 annual CBAM declaration and surrender | Irish EPA; Commission definitive-regime page |
| From 2028 | Default mark-up 30%, CBAM factor 0.900 | Guidance No. 3 and No. 4 |
4. What to do now
- List your EU CN codes and each customer's annual tonnage.
- Run the default-value cost per tonne in the calculator.
- Ask your steel suppliers for verified emissions data, and book verification early.
Official sources
- European Commission news, 20 Oct 2025 – Simplifications for CBAM officially published (50-tonne threshold)
- Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956
- European Commission – CBAM definitive regime
- European Commission – Price of CBAM certificates
- Environmental Protection Agency (Ireland) – CBAM certificates
- European Commission – Guidance No. 3: methods for calculating embedded emissions (14 Aug 2026; mark-ups 10/20/30%)
- European Commission – Guidance No. 4: free allocation adjustment (14 Aug 2026; CBAM factor Table 2-1, section 2.2.1.2)
- European Commission – Verification of CBAM emissions
Related guides
- CBAM default values for CN 7318 fasteners from China, and the 2026 cost per tonne
- CBAM actual emissions vs default values for fasteners
- CBAM certificate price 2026: the official quarterly prices and how to use them
- CBAM for steel structures (CN 7308): how the cost is calculated
- CBAM 7326: China default values and cost per tonne
- CBAM free allocation adjustment: benchmarks, CBAM factor and CSCF