No. An importer bringing 50 tonnes or less of CBAM covered goods into the EU in a year owes no certificates under the de-minimis threshold. The limit applies per importer per year, not per consignment; crossing it triggers the full obligation, including the first annual declaration due 30 September 2027 for 2026 imports.
How the 50 tonne de-minimis works
No certificate obligation arises at or below the CBAM de-minimis threshold of 50 tonnes of covered goods per importer per year. The definitive regime has applied since 1 January 2026 across six covered product groups, including iron and steel, and the threshold is a simple annual mass test:
- It is counted per importer, so each EU buyer measures its own imports rather than the volumes of any single supplier.
- It is counted per year, not per consignment, so many small shipments aggregate toward the same 50 tonnes.
Which CN codes count toward the test is set out in which iron and steel products CBAM covers.
What crossing the threshold triggers
Crossing 50 tonnes in a year brings the full CBAM obligation, not a lighter version of it.
| Position | At or below 50 tonnes a year | Above 50 tonnes a year |
|---|---|---|
| CBAM certificates | None | Required; the payable share of embedded emissions is 2.5 percent in 2026, rising to 100 percent by 2034 |
| Annual declaration | None | First declaration, covering 2026 imports, due 30 September 2027 |
| Certificate price | Not applicable | Tracks the EU ETS; the Q1 2026 average was EUR 75.36 per tonne CO2e |
Authorisation criteria and timing are covered in who qualifies as an authorised CBAM declarant.
Who should watch the threshold
Small EU buyers of Indian steel, and the exporters serving them, watch this threshold most closely. India was the EU’s largest iron and steel supplier in 2024 at about EUR 3.9 billion (Eurostat), and part of that trade reaches small distributors and fabricators near the limit. A prudent buyer totals its expected imports for the year, from every supplier, before assuming exemption, and prepares for the full obligation ahead of any expected crossing. An Indian exporter with many small customers maps which accounts will exceed 50 tonnes and prepares emissions data for those buyers, with verification performed by accredited verifiers; the cost mechanics are set out in what CBAM costs steel exporters. The CBAM guide walks through the regime step by step, and a CBAM consulting service can calculate embedded emissions and prepare the reporting file for accounts that cross the line.
Sources: Regulation (EU) 2023/956 · European Commission CBAM