EU Keeps CBAM's 50-Tonne De Minimis Threshold (0.87% of Emissions Exempted) — Verification of Non-EU Plants Assumes Physical Site Visits from Year One

On September 30, 2026, the European Commission (Directorate-General for Taxation and Customs Union) published its first assessment of the 50-tonne annual de minimis threshold under CBAM (the Carbon Border Adjustment Mechanism). Based on imports from April 1, 2025 to March 31, 2026, emissions exempted as imports of 50 tonnes or less accounted for only 0.87% of the total in scope, below the 1% limit set by the regulation. The threshold stays unchanged.

Two days earlier, on September 28, the Commission also published guidance for verifiers who check emissions at non-EU installations, together with procedures for verifiers to access the CBAM Registry. The threshold assessment concerns "who is obliged"; the verification guidance concerns "how the obligation is met." Read together, they show what the first year of the definitive regime will require.

The 50-tonne threshold assessment: 0.87% exempted

The 50-tonne threshold exempts importers whose annual imports of CBAM goods into the EU are 50 tonnes or less from declaration obligations. The practical guides published in August also confirmed that importers above 50 tonnes must obtain authorised CBAM declarant status.

Following this assessment, no change to the threshold is expected for now. Even with small consignments exempted, more than 99% of covered emissions remain within the scheme.

Verification guidance: physical site visits to non-EU installations are the rule

The verification guidance is aimed mainly at bodies verifying the emissions reports of non-EU installations producing CBAM goods imported into the EU from January 1, 2026. Where an exporting installation uses actual emissions data, those figures must have been verified by an accredited verifier.

Virtual visits and waivers both depend on a record of past physical visits. For 2026 emissions, the first year of the definitive regime, this means most installations will need a physical site visit.

Verifiers have been able to obtain access to the CBAM Registry since September 1. The Commission has also published the registration procedure, an application guide for technical user access, user manuals for the verifier and operator portals, and three training videos.

Working back from the declaration deadline

According to the guidance, authorised CBAM declarants submit their annual CBAM declaration in the CBAM Registry by September 30 each year. Because the reporting period is the calendar year, verification cannot be completed before January of the following year.

Installations producing complex goods from precursors need to receive the verification reports of the installations producing those precursors first. The guidance indicates that if a precursor's verification report does not arrive in time, verification should proceed by substituting the default values published by the Commission.

What it means for exporting installations

• Secure a verifier early: with site visits as the baseline, verifier staffing and schedules become the constraint. If verification of 2026 data is requested all at once in early 2027, visit slots may fill up
• Substitution with default values: if verification is not completed in time, calculations use the Commission's default values rather than the installation's actual emissions. Plants that have cut emissions through efficiency or electrification would see those gains go unreflected in the number of certificates
• Small exporters should check the threshold: importers bringing in 50 tonnes or less per year have no declaration obligation. But the threshold is applied per importer, so check your customer's total imports, not just your own shipments

Referenced Fact Cards