Regulation (EU) 2025/2083 added a mass threshold to CBAM: if an EU importer's annual total net mass of covered goods is 50 tonnes or less, no CBAM obligation arises.
Whose tonnage is counted?
The threshold looks at the importer's total purchases from all suppliers in a year, not at a single exporter's sales. A buyer ordering 20 tonnes from you but 200 tonnes elsewhere is well above it.
Exceptions
Electricity and hydrogen are not covered by this exemption. Nor does it apply automatically; the importer states it in the customs declaration.
What to do
Ask your buyer about their total CBAM tonnage and whether they will need data from you. If they do, the first annual declaration for 2026 imports is due by 30 September 2027, so preparation should not be left to the last month.
How Nechh Eco-Report handles it
In Eco-Report the exemption check runs as soon as the tonnage is entered. If you are exempt it says so clearly; if not, you move on to the actual-data calculation.