Authorised CBAM declarant for non-EU exporters: your EU importer and the 2027 dates

Who needs authorised CBAM declarant status

The carbon border tax, the Carbon Border Adjustment Mechanism (CBAM), covers six groups of goods. The list goes by customs code (CN code). It also includes some finished products, such as steel screws and bolts.

• Iron and steel
• Aluminium
• Fertilisers
• Cement
• Hydrogen
• Electricity

The 50-tonne threshold counts all imports of iron and steel, aluminium, fertilisers and cement together, per importer and per calendar year. Above the threshold, certificates are due on all imports of that year. The rules apply to goods made outside the European Economic Area and Switzerland.

Hydrogen and electricity are outside the 50-tonne threshold. An importer of hydrogen or electricity needs the status before the first shipment.

The threshold exempts about 90% of former importers. About 99% of the emissions in imported goods stay covered. The status therefore matters most for large and regular importers.

Two options for exporters from outside the EU

When your EU buyer imports the goods, your buyer needs the status and buys the certificates. When your company handles the import itself, for example when you sell delivered duty paid (DDP), you choose one of two options.

Option 1: your Dutch company applies itself

Your Dutch company is established in the EU, so it can apply for the status itself. The application goes through the Authorisation Management Module of the EU CBAM registry. In the Netherlands, this needs eHerkenning level 3, the Dutch business login. The Dutch Emissions Authority (NEa) decides on the application and then gives your company a CBAM account number.

Option 2: an indirect customs representative

If your company outside the EU is the importer, an indirect customs representative is always the declarant. The representative needs the status itself, also when your imports stay below 50 tonnes. It files the CBAM declaration in its own name.

Importers and representatives that applied by 31 March 2026 may keep importing while the decision is pending. A new applicant needs the status before the first import above the threshold. Apply early, so the status is ready before your next shipment.

The 2027 dates

CBAM next to the other EU rules up to 2030: the EU compliance calendar 2026 to 2030.

What CBAM costs your company over time

You pay with CBAM certificates. One certificate covers one tonne of CO2. For 2026 imports, the price is the quarterly average of EU emissions trading prices: €75.36 per tonne for the first quarter of 2026, €75.28 for the second quarter and €82.32 for the third. Your company buys these certificates from 1 February 2027.

EU plants still get part of their emission allowances for free. Your certificates are reduced in the same way, based on the benchmark for your product: the emission level for which EU plants get free allowances. This reduction becomes smaller every year. It is 97.5% of the benchmark in 2026, 95% in 2027, 90% in 2028, 51.5% in 2030 and 0% from 2034. The adjustment factor for free allocation is therefore 2.5% in 2026 and rises step by step to full application in 2034.

Verified emission data from your own plant is therefore worth money. The EU default values include a mark-up, so verified figures from an efficient plant usually give a lower bill.

For your own figures, use the CBAM cost calculator. Choose the country and the product, enter your tonnes a year, and see the certificate cost for each year from 2026 to 2034, with the EU default value or your verified emissions.

What we arrange

You have one contact person on our team for the company, the registrations and the yearly CBAM work. Specialist partners, such as a customs broker with declarant status and an accredited emissions verifier, are chosen per assignment. You see every price first.

1. Your Dutch company. Set up from abroad by power of attorney, with the notary. Your Dutch company (BV) from €2,950 excl. VAT, or a holding with an operating company from €4,950 excl. VAT.
2. The registrations. The VAT number, the customs number (EORI), the Article 23 licence for import VAT and eHerkenning level 3.
3. The application. Your company's application for authorised CBAM declarant status in the EU CBAM registry, up to the decision of the Dutch Emissions Authority (NEa).
4. Every year. The CBAM declaration by 30 September and the planning of your certificate purchases and quarterly checks, with a customs broker and an emissions verifier. CBAM work has its own price.
5. Stock and sales. Customs clearance, a warehouse in the Netherlands and sales across the EU from one company, with our partners. See importing and distributing through the Netherlands and importer of record in the EU.

Why the Netherlands

The port. Rotterdam is the largest port in Europe, with about 428 million tonnes in 2025.

Import VAT in the VAT return. A Dutch company can apply for the Article 23 licence. The import VAT then goes into the VAT return, where your company declares and deducts it in the same return. For bulk goods, this keeps a large amount of cash in your company.

One company for all EU duties. The same company is the base for your VAT number, your customs number, your packaging registrations and your European contracts.

Exporters in the Gulf

For producers in Saudi Arabia, the UAE, Qatar, Kuwait, Oman and Bahrain, three CBAM goods matter most: fertilisers, aluminium and, later, hydrogen. Ammonia counts as a fertiliser good under CBAM, with customs code 2814. Fertilisers and aluminium need the status above 50 tonnes a year, hydrogen from the first kilogram.

A Gulf exporter that sells delivered duty paid, or from stock in the EU, can use its own Dutch company as the importer. That company applies for the status itself and buys its own certificates. See EU importer for Gulf exporters, with the documents from each Gulf country and the work of our partners.

Exporters in Turkey

For exports from Turkey of iron and steel, aluminium, cement and fertilisers, the declarant reports either verified emissions data from the plant or the default value that the European Commission sets for Turkey and the product. For cement, iron and steel and aluminium, these default values include a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 (Implementing Regulation (EU) 2026/1740).

Once an accredited verifier has checked the figures of your plant, your company can declare the real emissions. Your own Dutch company can be the importer, with the status and the Article 23 licence. See Turkish exporters to the EU and CBAM for Turkish exporters.

Country guides

• United Arab Emirates, aluminium and steel exporters
• Saudi Arabia, fertilisers, aluminium, steel and petrochemicals
• Bahrain, aluminium
• Oman, aluminium, steel and green hydrogen
• Turkey, among the largest suppliers of iron and steel to the EU
• Egypt, nitrogen fertilisers, aluminium and steel
• India, steel and aluminium in volume
• Qatar, gas-based aluminium and fertilisers
• Morocco, fertilisers and steel across the Mediterranean
• South Africa, iron, steel and aluminium

Frequently asked questions

What is an authorised CBAM declarant?

An authorised CBAM declarant is a company in the EU with permission to import goods under the carbon border tax (CBAM). Above the yearly threshold, customs only lets an authorised CBAM declarant import these goods (Article 25 of the CBAM Regulation). The declarant buys the CBAM certificates and files the yearly CBAM declaration.

Who needs authorised CBAM declarant status?

Every importer of more than 50 tonnes a year of iron and steel, aluminium, fertilisers and cement together needs the status. For hydrogen and electricity, the status is needed from the first shipment. An indirect customs representative needs the status in every case, also when it files for a small importer.

How do I apply for the authorised CBAM declarant status?

Your company applies in the Authorisation Management Module of the EU CBAM registry. The company must be established in the EU. In the Netherlands, the application needs eHerkenning level 3, and the Dutch Emissions Authority (NEa) decides on it. An exporter from outside the EU applies through its own EU company, such as a Dutch BV.

Can an indirect customs representative be our CBAM declarant?

Yes. If your company outside the EU is the importer, the indirect customs representative is always the declarant. The representative needs authorised CBAM declarant status itself. Your own Dutch company is the other option: it imports in its own name and applies for the status itself.

What are the CBAM deadlines in 2027?

Certificate sales start on 1 February 2027. On 31 March 2027, your account must hold certificates for at least 50% of the emissions in your 2027 imports so far. The first annual CBAM declaration, for 2026 imports, is due by 30 September 2027, together with the certificates.

What does CBAM cost per tonne of CO2?

One CBAM certificate covers one tonne of CO2. For 2026 imports, the price is the quarterly average of EU emissions trading prices: €75.36 per tonne for the first quarter of 2026 and €82.32 for the third quarter. EU plants still get part of their allowances for free, and your certificates are reduced in the same way until 2034.

What does Holdwise charge for CBAM work?

CBAM work has its own price, which you see first. Your Dutch company (BV) costs from €2,950 excl. VAT, and a holding with an operating company from €4,950 excl. VAT. Your first advice is free.