Which goods fall under CBAM, and the phases
CBAM applies to the imports with the most carbon: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. Certain products made from these metals are also included. In the transitional phase, importers reported their emissions every quarter. In the definitive phase, they now also pay. Importers register as CBAM declarants and surrender paid certificates for the emissions in the goods they import. The certificates are priced on the EU carbon market. The EU is phasing out free allowances, so the share of emissions that you pay for rises every year.
Importing steel, aluminium, cement or fertiliser? See how your own Dutch company becomes the authorised CBAM declarant.
The importer’s to-do list
First, check your imports against the CBAM list of goods. Which goods fall under CBAM depends on the commodity codes. Second, ask your suppliers for emissions data, with actual figures for each installation where possible. If you use default values, you usually pay more. Third, register as a declarant and set up the yearly declaration. Add the cost of the certificates to the landed cost of each product line. For a first figure per product and per year, use the CBAM cost calculator. Many importers now include a clause on emissions data in their supplier contracts, because this data has a direct effect on the CBAM bill.
To see which role you need for your product and who can hold it, read EU market entry through the Netherlands. For the administration, the VAT returns and the annual accounts of the Dutch company, see corporate secretarial services in the Netherlands.
How CBAM combines with other import rules
CBAM works alongside the existing import rules: EORI registration, customs declarations and VAT (the EORI number and the article 23 scheme). The same discipline pays off here too: accurate product data, documented figures and one person responsible for the compliance calendar (the wider compliance guide). Importers who collected good emissions data during the reporting years now pay less than importers who rely on default values.
Under every EU rule, a company that is established in the EU must be named. All rules and dates are listed on which EU representative your product needs.