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Trade Council
CBAM’s 50-tonne threshold: a model for small traders
What changed
On 5 September 2025, the European Parliament announced that it had adopted simplifications to the EU’s Carbon Border Adjustment Mechanism (CBAM). One of the central changes is an annual mass threshold of 50 tonnes, effective from 1 January 2026. The Parliament said the threshold would remove around 90% of importers from the mechanism, most of them small and medium-sized enterprises, while keeping around 99% of emissions in scope.1
That is a significant design choice. Instead of treating every importer as though it has the same capacity to handle regulatory obligations, the rule uses a measurable scale threshold. The stated effect is to exempt most importers while preserving nearly all of the emissions coverage. The figures describe the expected effect of this CBAM simplification; they do not establish that a 50-tonne threshold is suitable for every kind of trade rule.
For small firms, the practical point is not that trade regulation has disappeared. It is that the design of a rule can determine whether an owner must spend time and money understanding, documenting and meeting obligations. A threshold may make the difference between a requirement that is manageable and one that is disproportionate to the size of a business or shipment.
Why the threshold matters
Small businesses make up a large part of the world economy. The United Nations estimates that micro, small and medium-sized enterprises account for about 90% of businesses, 60–70% of employment and roughly half of global GDP.2 Rules that are workable for a large importer with dedicated
compliance staff may create a very different burden for an owner who manages purchasing, sales, cash flow and shipping personally.
A threshold is one possible way to recognize that difference. The CBAM case is notable because the stated trade-off is explicit: a large majority of importers would be removed from the mechanism, while nearly all emissions would remain covered. That gives policymakers and businesses a concrete question to examine in other settings: can obligations be concentrated where they matter most, without requiring every small trader to navigate the same process?
The answer will vary by policy area. A mass threshold may be relevant to one rule and inappropriate for another. A rule addressing tariffs, product requirements or customs procedures may need a different measure of scale, a different exemption or no exemption at all. The transferable lesson is not “use 50 tonnes everywhere.” It is to test whether a proposed obligation is proportionate, whether its threshold is clear, and whether smaller firms can understand what applies to them.
What it means in different countries
For an owner bringing goods into the EU, the threshold is a reason to establish whether the business’s relevant annual mass falls below or above 50 tonnes under the applicable rules. This brief does not interpret the detailed operation of CBAM or determine how a particular firm’s goods are counted. Owners should check current official guidance for their own circumstances rather than infer their status from a general summary.
For a business based outside the EU, the change does not mean that every domestic trade rule has changed. Its immediate relevance depends on whether the business is involved in trade subject to the EU mechanism and on the obligations that apply to that trade. A firm in another country should not assume that a European threshold automatically governs its local imports, exports or domestic transactions.
For owners in countries that supply goods to EU markets, the threshold is still relevant as a policy and planning signal. A small business may be asked by a buyer, agent or logistics provider for information needed to assess a transaction. The existence of a threshold does not, by itself, settle who must provide information, what a contract requires, or what charges may arise. Those questions should be answered with written terms and reliable guidance, not assumptions.
For traders in countries without a comparable threshold, the case offers a practical point to raise with policymakers: can a new rule distinguish between the smallest operators and larger-scale activity, while still meeting its stated purpose? For traders operating in several markets, the same question needs to be asked separately for each destination. Rules differ; a threshold in one jurisdiction is not evidence that another jurisdiction has adopted the same approach.
What Reseated’s data shows
As of 6 April 2026, Reseated had 366 members in 49 countries and had received 849 reports from 50 countries. The Trade Council had 43 members in 23 countries and 20 reports from 15 countries. The median amount at stake in Trade Council reports was approximately US$3,680. Sixteen of the council’s reports had been filed in the preceding 30 days.
The reports were evenly divided between two recorded situations: 10 concerned supplier terms and 10 concerned tariffs. The reports came from a range of places. The United States accounted for three; Poland, Peru and Jordan accounted for two each; and the United Kingdom, United Arab Emirates, India and Japan accounted for one each. The council’s members also reflect businesses of different sizes: 45% identified as “just me,” 35% had teams of two to nine, 15% had 10 to 49, and 5% had 50 to 249.
These figures show why a small-trader perspective should be part of trade-rule design. They do not show that the 20 reports were about CBAM, nor do they prove that the experiences reported in one country apply everywhere. They are a modest, member-reported dataset, not a representative survey
of all importers. What they do establish is that trade-related concerns reach owners across multiple countries and business sizes, and that the amount at stake can be meaningful for a small enterprise.
That matters when authorities or large commercial partners assess the cost of a new process. An obligation that appears minor at system level can be material to an individual owner. The council’s evidence base therefore treats the practical burden—time, uncertainty and costs that must be understood before a trade decision—as part of the policy question, not an afterthought.
The Trade Council’s position
The Trade Council’s developing position is that new trade rules and tariffs should include size-based thresholds, plain-language guidance and a phase-in for small traders. It also calls for landed-cost transparency from freight forwarders. These are the council’s proposed principles, not a claim that a standard has already been adopted by Reseated or by any government.
The CBAM threshold gives the council a real case to examine: a measurable threshold, a defined start date and a stated estimate of its impact on importers and emissions. The council supports the underlying design principle of proportionality, while recognizing that the appropriate threshold must depend on the policy and the evidence for it. Small businesses need to be able to tell whether a rule applies to them, when it begins, and what steps they are expected to take.
Plain-language guidance is essential because a threshold is useful only if owners can understand how to apply it. A phase-in can give smaller firms time to adapt when obligations do apply. Landed-cost transparency addresses a related problem: an owner assessing a cross-border order needs a comprehensible account of the costs being passed on by the forwarder. A regulatory exemption cannot make an unclear shipping quote clear.
What owners can do
First, identify the destination and the rule that may apply. Do not assume that a measure announced in one market applies in another, or that being a small business automatically creates an exemption. For EU-related CBAM questions, consult current official guidance and check how the threshold applies to the business’s circumstances.
Second, keep a simple record of trade activity that could be relevant: destinations, shipment dates, quantities, invoices and the names of the parties responsible for arranging transport or import. For a threshold expressed in annual mass, accurate records can help an owner ask the right question. This is an organizational step, not a substitute for an authoritative determination of how the rule counts goods.
Third, ask suppliers and forwarders for written, itemized explanations of expected charges and responsibilities before confirming an order. If an amount is described only as a general customs, tariff or handling cost, ask what it covers, who sets it and whether it may change. Keep the written reply with the transaction records. Where a charge or responsibility is unclear, seek advice from a qualified professional or the relevant official service.
Finally, share recurring problems through appropriate business associations, consultations or Reseated’s Trade Council reporting process. Reports are more useful when they describe the type of rule or transaction, the point at which uncertainty arose, the business size and the amount at stake—without exposing confidential commercial details unnecessarily. Repeated, specific evidence can help show where clearer thresholds, guidance, phase-ins or cost disclosure would make trade rules more workable.
Sources and notes
This document has no standing until adopted under the Founders Charter. Reseated Councils is not affiliated with the United Nations.