Commission assessment places CBAM 50-tonne exemption at 0.87% of embedded emissions

What happened

The European Commission has published an assessment of the de minimis threshold used in the Carbon Border Adjustment Mechanism (CBAM). The review concerns the existing 50-tonne threshold, which is expressed as a mass-based measure.

For the assessment window running from 1 April 2025 until 31 March 2026, the Commission estimated that 0.87% of emissions embedded in imported goods and processed products would be exempted by that threshold. The Commission published the assessment on 30 September 2026.

The reported result is below the 1% level set out in the CBAM Regulation. The Commission’s notice describes the outcome of its assessment and does not announce a replacement threshold.

Why it matters

The threshold is intended to limit the share of embedded emissions excluded from CBAM treatment. Article 2a(3) requires the Commission to examine whether the current 50-tonne level remains within the regulation’s 1% emissions benchmark for imported goods and processed products.

For businesses handling imports or processed products affected by CBAM, the finding indicates that the current threshold remains below that benchmark for the period assessed. Importers and supply-chain partners should retain awareness of the threshold and follow subsequent Commission action, particularly where their relevant volumes are near 50 tonnes.

The assessment does not establish a new reporting or compliance requirement in the material published by the Commission. It instead provides the calculation used to test the continuing suitability of the existing threshold against the regulatory limit.

How a threshold change could arise

Under Article 28, the Commission is to use the methodology in point 2 of Annex VII when considering a delegated act to revise the threshold. That process applies where the calculated threshold differs from the applicable level by more than 15 tonnes.

The 0.87% result is therefore relevant both as a measure of the current exemption’s emissions coverage and as an input to the regulation’s review framework. Further detail is available from the European Commission’s CBAM threshold assessment.