The 50-tonne threshold and H7 shipments

Since 2026, an importer that brings in no more than 50 tonnes of CBAM goods in a calendar year is exempt from CBAM for that year. It sounds simple. In practice, three questions decide whether you are below or above: whose tonnes, which tonnes, and which year.

Whose tonnes: per importer

The 50 tonnes are counted per importer, that is per EORI number. Group companies are not added together, but each legal entity with its own EORI counts its own imports. If an indirect customs representative files for you, the tonnes are still counted per importer it represents.

Which tonnes

• Counted: the net mass of cement, iron and steel, aluminium and fertilisers covered by CBAM, from all your imports of the year.
• Not counted: electricity and hydrogen. They have no exemption at all: any import of them brings CBAM obligations.
• Returned goods under the returned-goods relief still count toward the 50 tonnes, although they are reported with zero embedded emissions.
• Goods excluded from CBAM altogether (for example from Norway, Iceland, Liechtenstein or Switzerland, or military goods) do not count.

Low-value H7 shipments count too

Before 2026, consignments worth less than 150 euros were left out. That exemption was removed with the 2025 simplification (Regulation (EU) 2025/2083). Low-value consignments declared with an H7 declaration therefore count toward the 50 tonnes and toward your declaration.

H7 declarations often show only a 6-digit code and the gross mass. CBAM Wise uses the gross mass as net mass when no net mass is given, and marks those lines, so the count can only be too high, never too low.

Which year: the acceptance date

A line counts in the year in which customs accepted the declaration that released the goods for free circulation, not the year of shipment or invoice. Many printed declarations do not show that date; see how to get your acceptance dates from SKAT.

Above 50 tonnes

Once you pass 50 tonnes in a year, every tonne of that year counts, from the first kilogram. To import above the threshold you must be an authorised CBAM declarant, and importing without the authorisation can bring penalties of three to five times the cost of the missing certificates. There is no fixed point at which you must apply, so watch the pace of the year: from the moment it is foreseeable that you will pass 50 tonnes, your customs declarations should carry your CBAM account number (document code Y128) instead of the exemption code (Y137).

CBAM Wise counts the tonnes per importer and year from your customs files, warns at 80% and shows when this year's pace would pass the threshold.