Senseible

Does the CBAM 50 tonne exemption cover hydrogen imported into Antwerp?

No. The 2025 simplification exempts importers bringing in 50 tonnes or less a year of covered goods, but hydrogen and electricity are excluded from that exemption. Any hydrogen import, however small, needs an authorised declarant, its direct embedded emissions and certificates.

How the threshold works

Regulation (EU) 2025/2083 replaced the old per-consignment value threshold with a yearly mass threshold per importer: up to 50 tonnes of covered goods a year in total is exempt. Hydrogen and electricity do not count towards it and are not exempted by it.

What counts for hydrogen

Hydrogen under CN 2804 10 00 is charged on direct emissions only. For hydrogen made from natural gas, that is the CO2 from reforming and fuel; electricity used in electrolysis is indirect and not charged under Annex II today.

Ammonia as a hydrogen carrier

Ammonia imported as a hydrogen carrier is its own CBAM good under 2814 and does count towards the 50 tonne threshold. Large cargoes exceed it in any case.

What Senseible does here

Senseible's CBAM cost calculator estimates certificate cost from 2026 to 2034 for covered goods, and non-EU suppliers can use Senseible to keep document-backed fuel and electricity records to share with you. Senseible does not file CBAM declarations or verify emissions.

Sources: Regulation (EU) 2025/2083, CBAM simplification, Regulation (EU) 2023/956 (CBAM Regulation), consolidated, European Commission, CBAM definitive regime

Last reviewed 2026-10-21.