A 50-ton annual net mass threshold is set for four categories—steel, aluminum, fertilizer, and cement. Importers whose total annual imports stay within this limit are exempt from all CBAM obligations, including reporting and certificate purchases.
To ensure fairness, the European Commission will assess each year by April 30 that this exemption covers no more than 1% of total embedded emissions. If the new calculated threshold deviates from the current one by over 15 tons (e.g., 50 to 68 tons), it will be adjusted through delegated legislation. To prevent circumvention, all CN-coded goods' weights are totaled—splitting shipments does not avoid compliance.
Electricity and hydrogen are excluded due to their distinct trade and emission characteristics. If a customs agent agrees to assume CBAM responsibility, their imports are counted under the principal importer’s volume.
If an unauthorized importer exceeds the threshold, penalties are based on the total annual embedded emissions calculated using default values. After paying the fine, further declarations may be waived. A 10% tolerance is allowed—if excess is within 5 tons (i.e., total ≤55 tons), a fine reduction can be requested.