Impact Analysis Report on Optimising the CBAM De Minimis Threshold
Authors: Andrei Marcu, Michael Mehling, Marco Sangiovanni, Helen Bevernage
ERCST’s Impact Analysis Report on optimising the CBAM de minimis threshold tests whether the current 50-tonne cumulative threshold strikes the best balance between administrative relief and emissions coverage, and how alternative designs would compare.
Key ERCST observations:
- The study tests six threshold designs against a dataset of 63,405 import shipments from downstream manufacturers, principally in the automotive and machinery and equipment sectors. Administrative relief is multi-dimensional. A threshold can relieve the burden on importers or the burden along the value chain (supplier relationships), and these are not the same.
- The current 50-tonne rule relieves importers well: it takes 54% of the importers in the dataset out of scope while retaining 99.5% of embedded emissions. However, it does little for the value chain, leaving more than 90% of supplier relationships in scope.
- Only a combined importer-and-pair design relieves both. It adds a 1-tonne threshold per importer-supplier relationship on top of the 50-tonne rule, exempting 56% of importers and 74% of relationships while retaining 98.5% of emissions.
- Shipment-based designs (value or weight per consignment) exempt more shipments but lose more emissions coverage. They are also the most exposed to circumvention through shipment splitting.
- The value-chain burden will grow over time. For every supplier relationship in scope, the third-country installation must determine and communicate its embedded emissions, and that cost rises several-fold as CBAM moves from default to actual values.
- The 50-tonne rule should be complemented, not replaced, with a relationship-level threshold. In fragmented sectors, where most importers already fall below 50 tonnes, a pair-based threshold applied on its own may be the more relevant instrument. The precise calibration is set out in the accompanying Policy Proposal.
