Rolls of steel lined up in a warehouse

CBAM 50-tonne threshold stays as first deadlines approach

ByTradeRoute EU

On 30 September 2026 the European Commission published its review of the CBAM de minimis threshold. The result: the 50-tonne limit stays as it is. For most small importers of steel or aluminium goods that is good news, because it keeps them outside the carbon border regime. It also removes the last excuse for waiting. The rules for 2026 are fixed, the year has three months left, and the first paid deadlines fall in 2027.

What the Commission decided

The CBAM Regulation requires the Commission to check that the mass-based threshold leaves no more than 1% of embedded emissions outside the system. Looking at imports between 1 April 2025 and 31 March 2026, it found that the 50-tonne threshold exempts 0.87%. That is inside the limit, so there is no change. The Commission also noted that it would only adjust the figure by delegated act if the calculated threshold differed from the current one by more than 15 tonnes.

In short, you can plan the rest of 2026 on 50 tonnes.

How the 50 tonnes are counted

CBAM has applied in its definitive form since 1 January 2026. It covers imports of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. According to the German Emissions Trading Authority (DEHSt), the threshold works like this:

  • It is counted per importer and per calendar year.
  • All consignments are added together, including those declared for you by indirect representatives.
  • It covers the mass of CBAM goods in the cement, iron and steel, fertiliser and aluminium sectors combined.
  • It does not apply to electricity or hydrogen. Those need authorisation from the first import.

Stay under 50 tonnes for the year and you have no CBAM obligations. Go over, and you need the status of authorised CBAM declarant before the goods that take you past the limit are imported. That is the point many SMEs miss. Fifty tonnes sounds like a lot until you add up a year of steel fasteners, brackets or aluminium profiles from China, India or Pakistan. Two or three full containers of heavy goods can do it.

Whether a product is in scope depends on its CN code, not on what you call it. Check with your customs broker if you are unsure.

If you are over, or about to be

In Germany you apply for authorisation through the CBAM Register, and DEHSt is the competent authority. Customs enforces the rule at the border, and DEHSt monitors the threshold and reports breaches to customs. Importers who filed their application by 31 March 2026 were allowed to keep importing while it was pending, using document code Y238 in the customs declaration. That transitional window has closed. If you only now see that your fourth-quarter orders will push you past 50 tonnes, get the application in before the goods ship, and speak to your customs broker about timing.

What it will cost, and when

Nobody pays anything this year, but the bill for 2026 is already building. The key dates from the Commission and DEHSt:

  • 5 October 2026: the Commission is due to publish the certificate price for the third quarter. The first two quarters came in at €75.36 and €75.28. The fourth-quarter price is due on 4 January 2027.
  • 1 February 2027: sales of CBAM certificates to authorised declarants begin on the common central platform. From 2027 the price is set weekly.
  • From 2027, at each quarter end: you must hold certificates for at least 50% of the emissions embedded in your imports since the start of that year.
  • 30 September 2027: first annual CBAM declaration for 2026, and surrender of the matching certificates.

One certificate covers one tonne of CO2 equivalent, and the price follows the average auction price of EU ETS allowances. Certificates can’t be traded or passed to another company. If your supplier can provide verified emissions data, your calculation will rest on real figures. Ask for it now, because suppliers need time to produce it.

What to do now

  1. Pull your 2026 import data by CN code and add up the tonnes of CBAM goods across all customs declarations, including those filed by forwarders and brokers on your behalf.
  2. Add the orders due to arrive before 31 December. If the total is near 50 tonnes, decide now whether to apply for authorisation or to move a shipment into January. A new calendar year starts a new count.
  3. If you are already authorised, keep a running total of tonnes by supplier and request emissions data from each one.
  4. Put a provision in your 2027 budget. Use the published quarterly prices as a guide, and update it when the third-quarter figure appears.
  5. Note 1 February and 30 September 2027 in your compliance calendar.

This article is general information and not legal advice. CBAM rules are detailed, so check with your customs broker before you act. TradeRoute EU is a Hamburg forwarder handling sea, air and road freight, customs clearance and warehousing for small and medium-sized companies. If you want your next shipment checked before it sails, get in touch and we’ll reply within 24 business hours.

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