The CBAM 50-tonne threshold is measured across all covered imports made by the same legal importer during the calendar year, not separately for each supplier. An importer can purchase less than 50 tonnes from each of several overseas suppliers and still exceed the annual exemption. If the combined quantity exceeds 50 tonnes, the exemption no longer covers that importer’s relevant imports for the year.
The European Commission’s 30 September 2026 assessment found that the existing threshold would exempt an estimated 0.87% of embedded emissions, below the 1% ceiling set in the legislation. The assessment did not introduce a new threshold. It puts the existing rule into sharper focus for buyers: which goods count, how much has the legal importer actually brought into the EU, and what happens if the total goes over 50 tonnes?
What did the September 2026 assessment establish?
The 50-tonne limit has not changed. Regulation (EU) 2025/2083 introduced the single mass-based threshold when it amended the original Carbon Border Adjustment Mechanism (CBAM) Regulation. To check whether the exemption remained within the permitted emissions share, the Commission used import data covering 1 April 2025 to 31 March 2026. Its assessment found that the threshold exempted 0.87% of embedded emissions.
The regulation allows the threshold to be reassessed and, if the specified conditions are met, changed through delegated acts. The September announcement was an assessment, not an amendment. For now, companies should plan against the current 50-tonne rule and monitor any later official changes.
It is also important to keep the key dates separate. The definitive CBAM regime began on 1 January 2026. The first annual declaration for applicable 2026 imports, along with the corresponding certificate surrender, is due on 30 September 2027. The threshold assessment, the start of the definitive regime and the first annual filing deadline are three different events. The Commission’s September 2026 implementation briefing also confirms the first declaration and certificate-surrender deadline.
How does the CBAM 50-tonne threshold apply to your imports?
To work out whether the exemption applies, a buyer needs to answer three questions: are the goods covered by CBAM, which legal entity is the importer, and how much has that entity imported during the calendar year? A supplier spend report will not answer all three.
Which goods count towards the CBAM 50-tonne threshold?
The mass-based exemption applies to specified goods in four sectors: iron and steel, aluminium, cement and fertilisers. The goods are identified by the Combined Nomenclature (CN) codes listed in CBAM legislation. Electricity and hydrogen are also CBAM sectors, but they are not covered by this particular 50-tonne exemption.
A description such as “steel components” or “industrial aluminium” is not enough to confirm that a product is in scope. The customs code and the goods released for free circulation matter. There is also an important distinction between buying goods from an EU distributor and importing them directly. If a distributor is the importer, it may have the direct CBAM obligation. The buyer may still face a price increase, but that is different from being the importer or declarant.
Who is the importer and who is the authorised CBAM declarant?
A multinational group may use one procurement team but import through several subsidiaries. In another business, several departments or warehouses may all import through the same legal entity. The threshold cannot be calculated from the group structure or by splitting purchases according to internal teams. It depends on the legal importer.
Under Article 3(15) of the amended CBAM Regulation, the importer is generally the person lodging the customs declaration in its own name and on its own behalf. Where an indirect customs representative lodges the declaration, the importer is the person on whose behalf it is made. This means the importer’s relevant volumes are added together even if different indirect representatives handle its shipments. The supplier, invoice recipient and production installation may all be different entities.
The authorised CBAM declarant is a separate role. An importer may hold that status itself, or an indirect customs representative may agree to act in that capacity and take on the relevant declaration and certificate obligations for the shipments it handles. Under Article 5, indirect customs representatives must obtain authorised CBAM declarant status before acting in that capacity for CBAM goods, including where the importer benefits from the mass-based exemption. If the importer is not established in an EU Member State, the indirect customs representative must obtain that status.
For an EU-established importer, Article 5(1b) requires an application for authorised CBAM declarant status when the importer expects to exceed the 50-tonne threshold. The application should be made before the threshold is exceeded, not after additional imports have already taken place. Buyers should therefore keep two things clear in their records: whose import volumes count, and who is authorised to fulfil the CBAM obligations.
How is the CBAM 50-tonne threshold calculated across imports?
For each legal importer, add the net mass of relevant covered goods across the four mass-based sectors, all suppliers and eligible shipments during the calendar year. Use customs entries and consistent units. Purchase value, gross shipping weight and invoice count do not determine whether the threshold has been exceeded.
Suppose one EU importer releases 29 tonnes of CBAM-covered steel, 15 tonnes of covered aluminium and 9 tonnes of covered fertilisers for free circulation in 2026. The total is 53 tonnes. The importer exceeds the threshold even though no individual category reaches 50 tonnes. This example assumes the products are correctly classified and the imports belong to the same legal importer.
A total of exactly 50 tonnes remains within the exemption. Once the relevant annual imports exceed that amount, the exemption no longer applies to the importer’s relevant imports for that year, including earlier shipments.
How should procurement monitor imports?
The most useful control is a running import record that can be checked against customs data. It should identify the legal importer, customs declaration reference, release date, CN code, net mass, supplier and product. Keep a separate forecast for the rest of the year. Do not add purchase orders that have not yet been imported to the total of goods already released for free circulation.
The exemption also needs to be indicated in the relevant customs declaration. Article 2a(1) applies this requirement to importers benefiting from the 50-tonne threshold, including those already authorised as CBAM declarants. Procurement and customs teams should therefore check both the importer’s cumulative net mass and whether the exemption was correctly indicated in the customs entry. Being below the threshold does not remove this customs declaration step.
Reconciliation often reveals why a single purchasing spreadsheet is not enough. Procurement may order fittings by the piece, a freight record may include packaging weight, and customs may record net kilograms. One system may identify the supplier’s headquarters while another records the production installation. These records serve different purposes. The task is to connect them, not treat them as interchangeable.
For example, a buyer forecasting 46 tonnes by November should review the likely effect of further orders before placing them. An internal alert below 50 tonnes is a sensible management control, but it is not an additional regulatory threshold. It gives the business time to understand whether further imports could change its position.
VECTRA’s Supply Chain Mapping guide explains how to distinguish contractual suppliers, production sites, product flows and information owners. For this CBAM decision, that mapping should lead to a reliable importer-level record, rather than remain a general picture of the supply chain.
What happens when the exemption no longer applies?
If the exemption no longer applies, the importer or the indirect customs representative acting as authorised CBAM declarant, as applicable, must meet the definitive-regime obligations for the relevant imports. These include declaring embedded emissions annually and surrendering the required CBAM certificates. An indirect representative acting as authorised CBAM declarant is responsible for the goods it imports on the importer’s behalf. Appointing a representative does not change how the importer’s 50-tonne total is calculated.
The authorisation arrangement should be settled before further imports create a customs problem. It should not be left until finance prepares the year-end figures. Certificates for emissions embedded in 2026 imports can be purchased from February 2027. Their prices are calculated by the quarter in which the goods were imported, even though the purchase and surrender take place later.
How does crossing the CBAM 50-tonne threshold affect sourcing costs?
The threshold tells an importer whether the mass-based exemption applies. It does not calculate how many certificates are needed or what they will cost. That assessment comes next for an importer whose goods are in scope.
Procurement should look at three things separately. First is volume exposure: which legal entity imports the covered goods, in what quantities and when. Second is emissions exposure: what embedded-emissions information is available for the products and their manufacturing installations, and whether permitted default values may be used. Third is financial exposure: the potential certificate obligation after applying the relevant calculation rules, adjustments and any eligible carbon price already paid in the country of origin.
The Commission publishes CBAM certificate prices based on EU Emissions Trading System auction prices. For 2026 imports, the applicable price is determined by the quarter in which the CBAM goods entered the Union: €75.36 for Q1, €75.28 for Q2 and €82.32 per certificate for Q3. Weekly prices will apply for 2027 imports. These are prices per certificate, not automatic charges per tonne of imported product.
For budgeting, the certificate price is only one part of the calculation. An in-scope importer must also establish embedded emissions under the applicable rules and account for relevant adjustments. These include the adjustment reflecting EU ETS free allocation and any eligible carbon price already paid in the country of origin. Procurement and finance can model a reasonable range of outcomes, provided the assumptions are clear and the estimate is not presented as the final certificate obligation.
For a broader explanation of how certificate obligations affect sourcing costs, supplier selection and margins, see VECTRA’s guide to CBAM’s definitive phase.
This is where false precision becomes a risk. A supplier’s company-wide carbon footprint cannot be turned into a reliable CBAM cost per product without checking the relevant production data and calculation method. Equally, using a default value does not establish the actual emissions performance of a particular supplier’s installation.
For a closer look at emissions-data quality and whether supplier records are ready for verification, see VECTRA’s CBAM data audit-readiness article.
What changes in supplier selection and contracts?
A buyer approaching the threshold may need to make two sourcing decisions. Can the business manage another covered import without unexpectedly changing its CBAM position? And, if it is or will be in scope, could a different sourcing route materially change the carbon-related landed cost?
Neither question can be answered by comparing quoted prices alone. For goods in scope, the buyer needs to know whether the supplier agreement provides access to the relevant production-installation information, how a change of manufacturing site will be communicated, and who must provide the data needed for the applicable calculation.
A supplier cannot confirm that the customer remains below 50 tonnes because it cannot see the importer’s other purchases. Ask suppliers for product-classification support and relevant manufacturing information, not a declaration about the importer’s annual exemption. VECTRA’s Supplier Engagement guide explains how to make evidence requests specific to a business decision instead of sending every supplier the same broad questionnaire.
If the importer is already above the threshold, procurement can consider an emissions-informed cost range alongside product quality, delivery capability and price. But a low-emissions claim should not become a supplier ranking until the underlying information has been assessed under the applicable CBAM rules. Contracts should also explain how changes to products, production sites or reporting periods will be communicated, and who is responsible for providing the required information.
Who owns the buyer’s threshold decision?
Customs or trade compliance should confirm which legal entity is the importer, check the relevant product classifications and establish the authorisation requirements. Procurement should maintain the supplier pipeline, forecast quantities and coordinate contractual data requests. Sustainability or technical specialists can assess emissions inputs where needed, while Finance should model potential certificate expenditure and maintain the assumptions behind the cost estimates.
Assign one person to own and approve the consolidated threshold record, ensuring it is reviewed whenever actual imports or forecasts change. Without clear ownership, one spreadsheet may show the correct legal position while another team continues placing orders without that information.
If this review also identifies wider supplier-risk or regulatory due-diligence gaps, VECTRA’s Compliance, Risk & Due Diligence service can help buyers assess and address them.
The decision before the first annual declaration
Before asking suppliers for another round of emissions data, procurement and customs should reconcile one importer-level record for 2026. It should bring together covered CN codes, net mass released for free circulation, the forecast for the rest of the year and the relevant authorised CBAM declarant arrangements. This will establish whether the mass-based exemption applies and what further controls are needed.
For covered iron and steel, aluminium, cement and fertilisers, that decision determines whether the importer needs to manage the related emissions, declaration and certificate obligations. Electricity and hydrogen need to be assessed separately because the 50-tonne exemption does not apply to them. Buyers can then use the result to guide upcoming purchases, supplier information requests and potential carbon-cost planning.
Key Points to Remember
Who: EU importers and indirect customs representatives handling CBAM-covered goods.
What: A 50-tonne annual exemption calculated across relevant iron and steel, aluminum, cement and fertilizer imports made by the same legal importer.
When: Import volumes are aggregated during each calendar year. The first declaration for applicable 2026 imports is due September 30, 2027.
Where: The rule applies to covered goods released for free circulation into the European Union.
Why: Exceeding the threshold changes the importer’s authorization, emissions-reporting, declaration and certificate obligations.
Frequently asked questions
Is the CBAM 50-tonne threshold calculated per supplier?
No. The relevant net mass is aggregated for the legal importer over the calendar year across covered goods in iron and steel, aluminium, cement and fertilisers.
Does CBAM apply only to tonnes above 50?
No. If the annual threshold is exceeded, the exemption no longer applies to the importer’s relevant imports for that year, including imports made before the threshold was crossed.
Are electricity and hydrogen covered by the exemption?
No. They are CBAM sectors, but they are not covered by the mass-based exemption. Their obligations need to be assessed separately.
Can a buyer below 50 tonnes still face CBAM costs?
Yes, indirectly. A buyer may purchase from a distributor that has CBAM costs and passes some of them on through its prices. That commercial exposure is different from the buyer having its own legal obligation as the importer.
View Related Posts
· How Manufacturers Can Improve CBAM Data Audit Readiness
· Supply Chain Mapping: 8 Blind Spots Hiding Supplier Risk
· Supplier Engagement: How to Get Better Evidence and Close Risk Gaps
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