CBAM declarant services · Netherlands

CBAM authorised declarant in the Netherlands: your own Dutch company as declarant

Since 1 January 2026, steel, aluminium, cement, fertilisers, hydrogen and electricity enter the EU only through an authorised CBAM declarant. For an exporter in Turkey, India, China, Korea or Canada, a Dutch company of your own takes that role: it imports, buys the certificates, files the declaration and keeps the emissions data in your group.

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By Robert Jeffrey, Holdwise B.V., Hoofddorp. Checked against the official sources on 27 October 2026.

Short answer

The carbon border adjustment mechanism (CBAM) is in its definitive period since 1 January 2026. An importer of more than 50 tonnes a year of iron and steel, aluminium, cement or fertilisers needs the status of authorised CBAM declarant; for hydrogen and electricity the status is needed from the first unit. Customs releases CBAM goods only for an authorised declarant (Regulation (EU) 2023/956, Article 25).

When the importer is established outside the EU, its indirect customs representative must have the status, whatever the volume (Article 5(2)). With your own Dutch company as importer, the status, the certificates, the emissions data and the liability stay in your own group.

The Dutch Emissions Authority (NEa) decides on an application within a statutory period of 120 days. The application goes through the EU CBAM Registry with eHerkenning at level 3. From 1 February 2027 certificates are sold on the common central platform. From 2027 the certificates on your account must cover at least 50% of the embedded emissions at the end of each quarter. The first annual declaration, for the imports of 2026, is due by 30 September 2027. Work out your yearly cost with the CBAM cost calculator.

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Who does what

We set up and manage your Dutch company and prepare the CBAM application with you. The customs broker and the verifier are partners, chosen per assignment, and you see each price first.

You

Your company

Your plant, your production data and your emissions per tonne
Your EU customers, your prices and your shipping plan
The decision between default values and verified actual values

The Dutch company

Your Dutch company, set up by power of attorney with the notary
Customs number (EORI), VAT number, the Article 23 application and eHerkenning
The CBAM application in the registry, with the NEa, and the security where the NEa asks for it
Bookkeeping, VAT returns, annual accounts, and the calendar for the quarterly purchases and the annual declaration

Partners from our network

Customs broker and verifier

Customs broker for the import declarations with the CBAM account number
Accredited verifier for the actual emissions of your installation
Warehouse in the Netherlands for your EU stock

Step by step

From the first question to a working declarant in your own group.

Your tonnage. You share your CBAM goods, your yearly tonnage to the EU and the installations that produce them. Our team replies in writing with the set-up and a quote.
Your Dutch company. The notary sets up the BV by power of attorney once all documents are complete. Registration with the KVK, customs number (EORI), VAT number and the Article 23 application.
eHerkenning and the registry. eHerkenning at level 3 for your company, access to the CBAM Registry through Dutch Customs, and the application to the NEa.
The emissions data. Your plant sends the production and emissions data per installation; a verifier checks the actual values, or your company uses the default values.
Imports and certificates. The customs broker declares the goods with the CBAM account number. From 1 February 2027 your company buys certificates on the common central platform and checks the 50% at each quarter end.
The annual declaration. By 30 September 2027 for 2026, and each year after that: the declaration in the registry and the surrender of the certificates.

50 tonnes

a year of iron and steel, aluminium, cement and fertilisers: above this, your importer needs authorised declarant status

€82.32

the CBAM certificate price for goods imported in the third quarter of 2026 (European Commission, 5 October 2026)

30 Sept 2027

the first annual CBAM declaration, for the imports of 2026, with the certificates surrendered

The CBAM calendar for importers

Date	What applies	Status
1 January 2026	Start of the definitive period. Above 50 tonnes a year, only an authorised CBAM declarant imports iron and steel, aluminium, cement and fertilisers. Hydrogen and electricity: always. The CBAM account number goes on the customs declaration.	In force (Regulation (EU) 2023/956 as amended by (EU) 2025/2083)
2026, each quarter	The certificate price for 2026 is the quarterly average of the EU emissions trading auction prices: €75.36 for the first quarter, €75.28 for the second, €82.32 for the third. The price for the fourth quarter follows on 4 January 2027.	Published (European Commission)
1 February 2027	Sale of CBAM certificates starts, on the common central platform. From 2027 the price follows a weekly average.	In force from that date (Article 20(1))
31 March 2027 and every quarter end from 2027	The certificates on your account cover at least 50% of the embedded emissions of the goods imported since the start of the year.	In force from 2027 (Article 22(2))
30 September 2027	First annual CBAM declaration, for the goods imported in 2026, with the quantities, the embedded emissions, any carbon price paid in the country of origin, and the surrender of the certificates. The same date each following year.	In force (Article 6(1) and Article 22(1))
1 January 2028	Proposed extension of CBAM to about 180 downstream products with a high steel or aluminium content, such as machinery parts, cylinders, radiators and some household appliances. The Council wants about 200 products, the European Parliament 457.	Proposal (Commission, 17 December 2025). Parliament adopted its position on 15 September 2026; talks with the Council follow.

The rules for your sector are on CBAM and your own EU company, with pages for exporters in Turkey and exporters in India. Steel also meets the import quotas of 2026: see EU steel import quotas 2026.

Who needs the status of authorised CBAM declarant

The importer. Under Article 25, customs allows the import of CBAM goods only by an authorised CBAM declarant, with the exemption up to 50 tonnes a year for iron and steel, aluminium, cement and fertilisers. The 50 tonnes count all CBAM goods together, over the calendar year. Two containers of fasteners can be enough.

The indirect customs representative, when the importer is established outside the EU. Article 5(2) says it plainly: in that case the indirect customs representative obtains the status, also when the importer itself is exempted. A Dutch customs broker that takes this role buys the certificates and files the declaration on its own account, for your goods, and prices that risk.

A company established in the EU imports in its own name. Your own Dutch company applies for the status itself, buys the certificates in its own account and files the declaration. The emissions data from your plant go to your own company, and the liability for the declaration stays in your group.

Want our team to have a look at your situation?

Tell us what you make or sell, where your company is and what you plan in Europe. Our team looks at it and replies with the steps and the dates that apply to you.

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How to become an authorised CBAM declarant in the Netherlands

A company established in the Netherlands. The notary sets up your Dutch company (BV) by power of attorney. The company registers with the Dutch Chamber of Commerce (KVK) and gets its customs number (EORI).
eHerkenning at level 3. The Dutch login for businesses. Dutch Customs gives access to the EU CBAM Registry with it. A third party can file on your behalf with a chain authorisation; the company stays responsible.
The application in the CBAM Registry. Your company files the application in the application module of the registry. The NEa assesses it against its assessment framework: the record of the company on customs and tax rules, and its financial and operational capacity. For a legal person set up after 31 December 2023, the NEa asks for a security, based on the value of the certificates your company will surrender.
120 days. The NEa applies a statutory processing period of 120 days. It may ask for more information; a quick reply keeps the file on schedule. When the NEa intends to refuse, you get 30 days to respond.
The decision. The admission decision gives your company the status of authorised CBAM declarant and a CBAM account number in the form CBAM-NL-202X-XXX12345678912. The number goes on every customs declaration for CBAM goods.
Imports. The customs broker declares the goods for your Dutch company, with the CBAM account number. The import VAT goes into the VAT return with the Article 23 licence.

Plan the application before the first shipment above 50 tonnes: the 120 days of the NEa come before the goods can clear customs in your own name.

The data, the certificates and the declaration

Emissions data. For each installation that produced your goods, the declaration states the embedded emissions. You can use the actual values from your plant, verified by an accredited verifier, or the default values of the European Commission per country of origin. Verified actual values pay off for a plant that emits less than the default: an electric arc furnace, for example. The verifier works in the CBAM Registry since 1 September 2026.

Certificates. From 1 February 2027 your company buys certificates on the common central platform at the published price. For the imports of 2026 the price is the quarterly average of the quarter of import; from 2027 it follows a weekly average. At the end of each quarter from 2027 the certificates on your account cover at least 50% of the embedded emissions of the goods imported that year.

The declaration. By 30 September of each year, first in 2027 for 2026, your company files the annual CBAM declaration in the registry: the quantities per type of goods, the embedded emissions, the verification reports, and any carbon price already paid in the country of origin, which is deducted. Your company then surrenders the certificates. The Commission adjusts the number of certificates for the free allocation that EU producers still receive; that adjustment decreases year by year until 2034.

Cost. The CBAM cost calculator works out the certificates for your tonnage and your emissions, with the 2026 prices and the free allocation adjustment.

One Dutch company, many roles

Importer of record with its own customs number (EORI), established in the EU. See importer of record in the EU.
Authorised CBAM declarant in its own name, with the certificates and the declaration in your group.
Article 23 licence holder: the import VAT goes into the VAT return, declared and deducted in the same return.
Quota user for steel: your company lodges the import declaration on the first day of each quarterly quota for your country of origin.
Seller in the EU: your company sells from Dutch stock to customers in all EU countries, with a Dutch VAT number.

The company is yours, the address is yours and the directors are yours; Holdwise sets up and manages, and stays outside your company. Prices: your Dutch company (BV) from €2,950 excl. VAT, and a holding with an operating company from €4,950 excl. VAT. The customs broker and the verifier have their own price, which you see first.

Sources

European Commission, CBAM definitive regime (2026): applies from 1 January 2026, 50 tonne threshold, the registry through the national competent authority.
European Commission, price of CBAM certificates: €75.36 (7 April 2026), €75.28 (6 July 2026), €82.32 (5 October 2026); all certificates on the common central platform from February 2027.
European Commission, CBAM communication and news: factsheets of 23 June 2026 and 30 September 2026 (first declaration by 30 September 2027, actual or default values), verifier access to the registry from 1 September 2026.
Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956 on the carbon border adjustment mechanism, Articles 2a, 5(2), 6(1), 20(1), 21(1a), 22 and 25, EUR-Lex (Official Journal of 17 October 2025).
Dutch Emissions Authority (NEa), admission procedure for CBAM declarants (updated 30 April 2026): CBAM Registry, eHerkenning level 3, statutory period of 120 days, security for companies set up after 31 December 2023, the CBAM account number.
Netherlands Enterprise Agency, Carbon Border Adjustment Mechanism (CBAM), business.gov.nl (2026): the goods, hydrogen and electricity from the first unit, the indirect representative for a non-EU importer.
European Commission, press release IP/25/3088 on the CBAM review and the downstream extension (17 December 2025): 180 products from 1 January 2028, proposal.
European Parliament, briefing on the downstream extension (7 September 2026) and procedure file 2025/0419(COD): Parliament position of 15 September 2026, referred back for the negotiations.

Last reviewed: 27 October 2026. Based on Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 and the official pages named under Sources, as they read on that date.

Common questions

How do I become an authorised CBAM declarant in the Netherlands? +

With a company established in the Netherlands, eHerkenning at level 3 and an application in the EU CBAM Registry. The Dutch Emissions Authority (NEa) assesses the application within a statutory period of 120 days and, on approval, gives your company the status and a CBAM account number. For a company set up after 31 December 2023 the NEa asks for a security based on the certificates your company will surrender.

Can a company outside the EU be a CBAM declarant? +

The declarant is the importer, established in the EU. When the importer is established outside the EU, its indirect customs representative must have the status and files for your goods on its own account, whatever the volume (Article 5(2)). Your own Dutch company is established in the EU and takes the role itself.

What is the 50 tonne threshold? +

An importer that brings in 50 tonnes or less of iron and steel, aluminium, cement and fertilisers together in a calendar year is exempt from CBAM. Above that, the importer needs authorised declarant status for all of its CBAM imports. Hydrogen and electricity count from the first unit. The threshold keeps about 99% of the embedded emissions inside CBAM (European Commission, 30 September 2026).

When do I buy CBAM certificates and at what price? +

From 1 February 2027, on the common central platform. For goods imported in 2026 the price is the quarterly average of the EU emissions trading auctions: €75.36 for the first quarter, €75.28 for the second and €82.32 for the third quarter of 2026. From 2027 the price follows a weekly average. From 2027 the certificates on your account cover at least 50% of the embedded emissions at the end of each quarter.

When is the first CBAM declaration due? +

By 30 September 2027, for the goods imported in 2026. The declaration states the quantities, the embedded emissions, the verification reports and any carbon price paid in the country of origin. Your company then surrenders the certificates. The same date applies each following year.

What do CBAM declarant services cost? +

Your Dutch company (BV) costs from €2,950 excl. VAT, and a holding with an operating company from €4,950 excl. VAT. The customs broker and the verifier have their own price, which you see first. The certificates are a cost of your company: use the CBAM cost calculator for your tonnage.

Does CBAM apply to my products from 2028 as well? +

The European Commission proposed on 17 December 2025 to extend CBAM to about 180 downstream products with a high steel or aluminium content from 1 January 2028, such as machinery parts, cylinders, radiators and some household appliances. The Council wants about 200 products and the European Parliament 457. It is a proposal; the final list and the start date come out of the talks between Parliament and Council.

Default values or verified actual values? +

Both are allowed. Default values come from the European Commission per country of origin and ask for little from your plant. Verified actual values need an accredited verifier and pay off when your installation emits less than the default, such as an electric arc furnace with low-carbon electricity. The calculator shows the difference for your figures.

Our team

Want our team to have a look?

Tell us which CBAM goods you export to the EU, your yearly tonnage and where your plant is. Our team replies with advice on your own Dutch declarant and the timing of the application.