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CBAM 50-tonne threshold and the 2027 timeline

Updated 2026-11-10 · Data: default values v2 (6 Aug 2026) · benchmarks (6 Feb 2026) · certificate prices to Q3 2026

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.

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

3. Timeline

WhenWhatSource
1 Jan 2026Definitive regime starts; importers incur certificate obligations for 2026 importsCommission definitive-regime page
First week after each 2026 quarterQuarterly certificate price published (Q1 €75.36, Q2 €75.28, Q3 €82.32)Commission price page
4 Jan 2027Q4 2026 price publishedCommission price page
From Feb 2027Certificates bought on the common central platform; weekly prices from 2027Commission price page
By 30 Sep 20272026 annual CBAM declaration and surrenderIrish EPA; Commission definitive-regime page
From 2028Default mark-up 30%, CBAM factor 0.900Guidance No. 3 and No. 4

4. What to do now

  1. List your EU CN codes and each customer's annual tonnage.
  2. Run the default-value cost per tonne in the calculator.
  3. Ask your steel suppliers for verified emissions data, and book verification early.

Official sources

  1. European Commission news, 20 Oct 2025 – Simplifications for CBAM officially published (50-tonne threshold)
  2. Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956
  3. European Commission – CBAM definitive regime
  4. European Commission – Price of CBAM certificates
  5. Environmental Protection Agency (Ireland) – CBAM certificates
  6. European Commission – Guidance No. 3: methods for calculating embedded emissions (14 Aug 2026; mark-ups 10/20/30%)
  7. European Commission – Guidance No. 4: free allocation adjustment (14 Aug 2026; CBAM factor Table 2-1, section 2.2.1.2)
  8. European Commission – Verification of CBAM emissions

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