Key simplification (effective October 2025)
A single mass-based de minimis threshold exempts importers whose cumulative net mass of CBAM goods (iron/steel, aluminium, cement, fertilisers only) is ≤50 tonnes per calendar year from:
Authorised declarant status.
Reporting, declarations, and certificate obligations.
Important notes
Threshold is per importer (across all consignments/CN codes/Member States).
Electricity and hydrogen: No threshold exemption.
If exceeded mid-year: Full obligations apply retroactively to all imports that year (heavy penalties possible without authorisation).
Monitor monthly – artificial splitting to stay under is prohibited (considered circumvention)
What to do
Track cumulative imports carefully (use tools like CarbonChain for automated alerts).
If near threshold: Apply early for authorisation (grace period if applied by 31 March 2026).
Plan contingency: Switch suppliers or change incoterms to avoid declaration obligations.