In brief
The threshold generally concerns the EU importer’s cumulative annual imports of relevant CBAM goods.
It is not automatically assessed separately for each UK supplier.
Hydrogen and imported electricity sit outside the general mass-based exemption, and UK exporters may still be required to provide embedded-emissions data.
Who measures the threshold
The EU importer must monitor the relevant annual import volume. Exporters should not assume that a small shipment is exempt without knowing the importer’s cumulative annual imports.
What it means for UK exporters
UK exporters may receive customer requests for installation-level emissions, supplier and production-site data, product and commodity-code consistency, actual emissions or default-value treatment, data timing, contract responsibility and evidence for multiple EU customers.
First annual declaration
The first annual declaration for 2026 imports is due in 2027 under the applicable EU timetable. This article does not invent a specific deadline beyond the supplied verified source treatment.
Actions to consider
- Identify EU customers importing covered goods.
- Confirm product commodity codes.
- Determine the production installation.
- Calculate or collect embedded-emissions information.
- Maintain product-to-installation traceability.
- Ask EU customers whether they expect to cross the annual threshold.
- Establish secure data-transfer processes.
- Retain evidence behind emissions values.
- Document whether actual or default data is used.
- Update commercial agreements where responsibility is unclear.
How SustainZone supports preparation
- EU CBAM product screening
- UK exporter evidence packs
- installation-level data templates
- embedded-emissions calculation support
- importer-supplier responsibility mapping
- transaction tracking
- CBAM data dashboards
- evidence-gap assessments
