Insights · EU law and compliance

CBAM for importers in the Netherlands, Belgium and Luxembourg

The EU carbon border charge is live: who is covered after the 2025 simplification, why customs refuses release without declarant status, which data you need from suppliers, when you pay, and what it will cost year by year, with a calculator.
Calculate my CBAM cost ↓

Reading time9 minutes
TopicEU law and compliance
Rules as ofOctober 2026
AuthorAlexander Baranov
The short version

CBAM applies to imports of iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. Since 2026 importers above 50 tonnes a year need authorised declarant status, or customs refuses release. Certificates for 2026 imports are sold from February 2027 and the first declaration is due by 30 September 2027. The cost starts at 2.5% of embedded emissions and rises to 100% by 2034, so supplier data and price clauses matter now.

01 · In plain words

A carbon price at the border, live since January 2026

The EU charges its own steel, aluminium, cement and fertiliser producers for their CO2 emissions under the emissions trading system. CBAM charges importers the same price for the emissions embedded in the goods they bring in, so that production does not simply move abroad. After two years of reports without payment, the definitive period started on 1 January 2026.

For a Rotterdam, Antwerp or Luxembourg importer of steel coils, aluminium profiles, cement or fertilisers, three things change: a customs status you need before you import, emissions data you need from every supplier, and a bill that grows every year until 2034.

Status

Authorised declarant

Without it, customs refuses release.

Threshold

50 tonnes a year

Above it, everything is covered.

Data

Verified emissions

From each installation abroad.

Cost

2.5% in 2026

100% of the carbon price from 2034.

02 · The rules

Timeline and obligations

DateWhat happens
1 January 2026Definitive period starts; 50-tonne de minimis threshold applies
31 March 2026Last date to apply for authorised declarant status and keep importing during the review
27 September 2026End of the transitional arrangement for pending applications
1 February 2027Sale of CBAM certificates starts, priced on EU ETS auctions
30 September 2027First annual CBAM declaration for 2026 imports; surrender of certificates
2026 to 2034CBAM factor rises from 2.5% to 100% as free ETS allowances end

Law and practice: Regulation (EU) 2023/956 (CBAM) as amended by Regulation (EU) 2025/2083 (simplification). The competent authority in the Netherlands is the Dutch Emissions Authority (NEa); Belgium and Luxembourg have their own national authorities. Embedded emissions must be verified by an accredited verifier; a carbon price paid in the country of origin can be deducted. Penalties for missing certificates are set above the certificate price.

03 · What we do

CBAM for importers in the Benelux

  1. Scope checkCN codes against Annex I, yearly tonnage, threshold.
  2. Declarant statusApplication in the CBAM registry, or set-up with an indirect customs representative.
  3. Supplier dataTemplates and follow-up with installations abroad; default values where data is missing.
  4. VerificationCoordination with an accredited verifier.
  5. Certificates and declarationQuarterly holding, purchase, annual declaration.
  6. ContractsPrice clauses with suppliers to pass on the CBAM cost.
Example

A Dutch distributor imports 3,000 tonnes of hot-rolled steel from Turkey a year at 1.9 tCO2 per tonne. At an EU carbon price of EUR 75 the CBAM cost is about EUR 10,700 for 2026 imports, EUR 21,400 for 2027 and over EUR 200,000 a year once the factor reaches 48.5% in 2030. Supplier data and price clauses agreed now protect the margin later.

04 · Your case

CBAM: are you in, and what will it cost?

The result updates with each answer. The phase-in factors are those of the EU ETS free allocation phase-out; check the final figures for your goods.

CBAM: are you in, and what will it cost?

Enter your imports and the emissions of your goods. You see whether CBAM applies and an estimate of the certificates you will have to buy.

What do you import?
Import year
Importing steel, aluminium, cement or fertilisers?We check your scope, obtain the declarant status, collect supplier data and file your declarations.
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01Status first

No status, no release.

02Data from suppliers

Default values cost more.

03Cost rises

2.5% now, 100% in 2034.

04Pass it on

Price clauses in your contracts.

05 · FAQ

CBAM for importers: frequent questions

Who has to pay CBAM?

Importers of iron and steel, aluminium, cement, fertilisers, hydrogen and electricity into the EU. Since the 2025 simplification, an importer bringing in no more than 50 tonnes of these goods a year (electricity and hydrogen aside) is exempt. Above the threshold, the whole volume is covered.

Do I need to be an authorised CBAM declarant?

Yes, above the threshold. Without the status customs refuses release for free circulation. Importers who applied by 31 March 2026 could keep importing while their application was pending; that transitional arrangement ended on 27 September 2026.

When do I pay?

Certificates for 2026 imports go on sale on 1 February 2027. The first annual declaration, with verified emissions and surrender of certificates, is due by 30 September 2027. From 2027 you must hold certificates for at least 50% of the embedded emissions at the end of each quarter.

Why is the cost low in 2026?

Because CBAM phases in as free ETS allowances for EU producers are phased out: 2.5% of embedded emissions in 2026, rising to 100% in 2034. The cost grows every year even if your imports do not.

Can a customs broker do this for me?

An indirect customs representative can act as declarant, but carries the obligations and usually charges for the risk. Many importers keep the status themselves and outsource the data collection and filing.

Your structure

Importing CBAM goods into the Benelux?

We check your scope, obtain declarant status, organise supplier emissions data and file your CBAM declarations.