# Will the EU keep the 50-tonne CBAM exemption, or could small buyers lose it?

Canonical: https://senseible.earth/answers/cbam-50-tonne-threshold-review-0-87-percent

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.

- [How the 50-tonne threshold is counted](https://senseible.earth/answers/cbam-50-tonne-threshold-how-counted)
- [What is an authorised CBAM declarant?](https://senseible.earth/answers/what-is-an-authorised-cbam-declarant)
- [CBAM for Indian exporters](https://senseible.earth/cbam)

Sources: [European Commission, CBAM communication and news: De Minimis Threshold Assessment (30 September 2026)](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-communication-and-news_en), [European Commission, CBAM Questions and Answers (last updated 15 October 2026)](https://taxation-customs.ec.europa.eu/document/download/013fa763-5dce-4726-a204-69fec04d5ce2_en?filename=CBAM_Questions%20and%20Answers.pdf)

Last reviewed 2026-11-01. Re-check the Commission's news page for the next threshold assessment.
