Assofermet has asked the European Commission to raise the annual CBAM exemption threshold from 50 to 500 tonnes per importer. In its 11 November statement, the Italian trade association argues that the proposed extension to downstream steel and aluminium products could impose disproportionate administrative costs on smaller businesses.
The request concerns which importers would be required to comply with CBAM obligations as additional finished products enter its scope.
Why finished products change the calculation
Assofermet points to businesses importing numerous types of hardware and machinery components in relatively small quantities. Collecting emissions information for these products can require the involvement of several manufacturers, even when the combined weight of imports is modest.
A finished product can also contain plastic or other materials alongside steel and aluminium: its total weight therefore does not measure the quantity of metal subject to a carbon cost. Applying a single weight threshold to basic metals and mixed-material products can therefore bring importers purchasing very different quantities of metal covered by the mechanism into the scope of CBAM.
How the current 50-tonne threshold works
Under the current rules, the threshold counts the combined net weight of goods subject to CBAM imported by the same importer during a calendar year.
For example, an importer bringing in 40 tonnes of steel products and 20 tonnes of aluminium products, all subject to CBAM, reaches a total of 60 tonnes. Once the threshold is exceeded, CBAM obligations apply to all these imports during the year, including the quantities imported before the limit was crossed.
How much of the emissions would remain covered?
Assofermet cites an earlier Commission analysis suggesting that a 500-tonne threshold would exempt around 97% of importers while retaining coverage of 96.43% of embedded emissions in the sectors originally assessed.
The Commission’s latest published assessment, dated 30 September, finds that the current 50-tonne threshold would exempt 0.87% of embedded emissions, below the 1% limit set by the legislation. The earlier result for the 500-tonne threshold retains emissions coverage below the 99% required by the current methodology for determining the threshold. The September assessment uses imports from April 2025 to March 2026, before any extension to downstream products.
Adding finished products would change both the population of importers and the metal content of their imports. Assofermet is therefore asking for a new impact assessment and for consideration to be given to introducing thresholds differentiated by product type.
