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CBAM 50-tonne threshold checker

By Jai Nischal Verma · Law last checked 31 October 2026

Add up the iron, steel, aluminium, cement and fertiliser you expect to import this calendar year. Then say whether any hydrogen or electricity is in the mix. The checker tells you whether the 50-tonne exemption still holds.

Law last checked: 31 October 2026. Figures below are copied from the EU texts linked in Sources. This is general information, not legal, tax or customs advice. Rules and prices change; confirm them before you import.

Net mass, not gross. The four boxes are one combined total per importer, per calendar year. Hydrogen and electricity are not part of that total.

Authorised declarant status
–
Combined mass of the four sectors
–
Room under 50 tonnes
–
Hydrogen and electricity
–
Who must hold the status
–
The bar fills towards 50 tonnes. Hydrogen and electricity are not on this bar; they sit outside the exemption.

The rule

Article 2a exempts an importer when the net mass of the goods does not exceed the Annex VII threshold of 50 tonnes. The threshold adds up iron and steel, aluminium, cement and fertilisers. It does not apply to electricity or hydrogen. Crossing it pulls in every tonne imported that year, not just the excess.

Checked 31 Oct 2026. Runs in your browser.

Why hydrogen is not “just another tonne”

Annex VII sets the single mass-based threshold at 50 tonnes[3]. The Commission’s definitive-regime page says the same thing in plainer words: more than 50 tonnes of CBAM goods means you apply for authorised declarant status[1]. Article 2a(4) then takes electricity and hydrogen out of that article entirely[3].

So 40 tonnes of steel and a cylinder of hydrogen is not “40 tonnes, you’re fine.” The steel may still be under the exemption. The hydrogen is not. And if you are not established in the EU, your indirect customs representative needs the status even for the steel[3].

What this costs you

The threshold checker does not price certificates. It tells you whether the filing exists. If it does, the money is on the certificate cost calculator, using a published price from the tracker. If you cross 50 tonnes in, say, June, the obligations cover the imports from January as well[3].

The application itself is the declarant guide. The dates after you are authorised are on the timeline.

Frequently asked questions

Does exactly 50 tonnes need authorisation?

Not on the mass test. The exemption applies when net mass does not exceed 50 tonnes. Going over 50 brings the whole year into scope, including the tonnes imported before you crossed the line.

Do hydrogen and electricity count towards the 50 tonnes?

No. Article 2a does not apply to them. Any hydrogen or electricity import needs authorised declarant status, whatever the mass of your other CBAM goods.

What if our company is outside the EU?

If the importer is not established in a Member State, the indirect customs representative has to be an authorised CBAM declarant even when the 50-tonne exemption would have applied.

Sources

The 50-tonne figure is Annex VII of the consolidated CBAM Regulation, repeated on the Commission’s definitive-regime page. Law last checked 31 October 2026. See our methodology and editorial policy. General information, not legal, tax or customs advice.

  1. [1] European Commission: CBAM definitive regime (from 1 January 2026): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en (checked 31 Oct 2026)
  2. [2] European Commission: Price of CBAM certificates (quarterly table): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en (checked 31 Oct 2026)
  3. [3] Regulation (EU) 2023/956, consolidated 20 October 2025 (CBAM Regulation): https://eur-lex.europa.eu/eli/reg/2023/956/2025-10-20/eng (checked 31 Oct 2026)
  4. [4] Directive 2003/87/EC, consolidated (EU ETS), Article 10a(1a) CBAM factor: https://eur-lex.europa.eu/eli/dir/2003/87 (checked 31 Oct 2026)
  5. [5] Commission Implementing Regulation (EU) 2025/2548 (certificate price method): https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32025R2548 (checked 31 Oct 2026)
  6. [6] Commission Implementing Regulation (EU) 2025/2620 (free-allocation adjustment): https://eur-lex.europa.eu/eli/reg_impl/2025/2620/oj/eng (checked 31 Oct 2026)
  7. [7] European Commission Guidance No. 4 on the free-allocation adjustment (CBAM factor table, including 2034 at 0%): https://taxation-customs.ec.europa.eu/document/download/3aa2c730-4f1b-4524-8f71-d9cfe4880ac7_en?filename=Guidance+No.+4+-+CBAM+calculation+of+the+free+allocation+adjustment+to+the+number+of+CBAM+certificates+to+be+surrendered.pdf (checked 31 Oct 2026)