Asia & World

The EU Carbon Border Levy (CBAM) for Chinese Exporters: Prepare Now

Updated: 19 August 2026 Holdwise editorial team China CBAM Export

Under the EU carbon border levy (CBAM), European buyers now ask Chinese suppliers for the embedded emissions per product. They ask this together with the price and the lead time. Exporters with real data from their installations get more orders than competitors who use default values. At Holdwise, we keep this answer up to date and change it when the rules change.

What is covered

CBAM applies to the most carbon-intensive imports: iron and steel, aluminium, cement, fertilisers, hydrogen, electricity and certain downstream metal products. In the EU, the importer registers as declarant. The importer then surrenders paid certificates for the embedded emissions. These certificates are priced against the EU carbon market. See CBAM explained from the importer's side. For you as an exporter, your emissions figure is now part of your price.

Exporting CBAM goods to the EU? See the authorised CBAM declarant in the Netherlands and what your EU company files.

Data is now a competitive factor

With actual data per installation, the importer nearly always pays less for certificates than with default values. For this reason, buyers prefer suppliers who give verified figures per product line. To prepare, measure the emissions per installation with the CBAM method and arrange the verification. Add an emissions-data clause to your sales contracts before your buyers ask for one. Steel and aluminium producers who built this data process in the reporting years already use it as a selling point. To see what verified figures save your EU buyer, compare the default value with your own figure in the CBAM cost calculator for China.

A seller from outside the EU usually needs the right representative role and a Dutch company that meets all its legal duties. You can read about the roles per product on EU market entry through the Netherlands. For the filings after that, see corporate services in the Netherlands.

Setting up your own EU entity

Exporters with real volume often take the next step: setting up their own Dutch entity as the EU importer and declarant. This gives you control over the CBAM position, the article 23 cash flow and the customer relationship: setting up an EU entity and the article 23 scheme. The levy favours suppliers who prepare for it early.

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.

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Frequently asked questions

Does CBAM apply to finished goods containing steel? +

It depends on the commodity codes you declare. Listed goods and certain downstream products are in scope. Complex finished machinery is usually outside the current scope. Later reviews may widen the scope. Check the classification of your catalogue once to know your position.

Who pays, us or the EU buyer? +

Legally, the EU declarant surrenders the certificates. In practice, the cost becomes part of the price you negotiate, like any duty. Suppliers with low verified emissions add a smaller amount to their price.

When was this last checked? +

Reviewed 19 August 2026. The definitive regime is still phasing in and the scope may change, but the steps to prepare stay the same.

Sources Belastingdienst · KVK · wetten.overheid.nl Last updated: 19 August 2026