Will the EU keep the 50-tonne CBAM exemption, or could small buyers lose it?
Not for now. Article 2a(3) of the CBAM Regulation requires the 50-tonne threshold to exempt no more than 1% of embedded emissions. The Commission's assessment for 1 April 2025 to 31 March 2026 found it exempted 0.87%. The threshold changes only if a recalculation moves it by more than 15 tonnes.
The rule behind the threshold
Under Article 2a(3), the Commission must check whether the single 50-tonne threshold exempts no more than 1% of the emissions embedded in imported goods. If the method in point 2 of Annex VII gives a threshold that differs from the current one by more than 15 tonnes, the Commission amends it by delegated act.
What the first assessment found
Published on 30 September 2026: for 1 April 2025 to 31 March 2026, the 50-tonne threshold would exempt 0.87% of embedded emissions, below the 1% limit. No change was triggered.
What would move it
- More small importers bringing in more goods under the line, pushing the exempt share towards 1%.
- A recalculation landing below 35 tonnes or above 65 tonnes, the 15-tonne band either side of 50.
- A delegated act, which takes time to adopt, so a change would not land overnight.
What to do if your buyer is under 50 tonnes
- Ask each year what their total CBAM imports were. The count covers all their suppliers, not just you.
- Keep your emissions records anyway. A buyer that grows past the line needs data for the whole year.
- Treat the exemption as a margin you watch, not a promise.
Timeline
- 8 October 2025: Regulation (EU) 2025/2083 simplifies CBAM, with a single 50-tonne threshold
- 1 January 2026: importers bringing in more than 50 tonnes need a CBAM account number or an application reference number
- 1 April 2025 to 31 March 2026: period assessed
- 30 September 2026: assessment published, 0.87% exempted, threshold stays at 50 tonnes
What Senseible does here
Senseible keeps your fuel, power and production records as dated records, so if a buyer crosses 50 tonnes you can send a figure for the full year without starting from scratch. It does not file CBAM declarations.
Sources: European Commission, CBAM communication and news: De Minimis Threshold Assessment (30 September 2026), European Commission, CBAM Questions and Answers (last updated 15 October 2026)
Last reviewed 2026-11-01. Re-check the Commission's news page for the next threshold assessment.