CBAM and Bahrain

In 2025 the European Union imported goods worth €1.8 billion from Bahrain. Non-ferrous metals, the product group that includes aluminium, were 76.6% of this (European Commission, 2026). Of the non-ferrous metals, only aluminium falls under the Carbon Border Adjustment Mechanism (CBAM).

One well-chosen company in the EU can handle the CBAM duties for your aluminium shipments. With verified emissions figures in the CBAM declaration, you can show the efficiency of your smelter.

The rules in the definitive phase

Six sectors fall within scope today: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Under Article 25 of the CBAM Regulation, customs authorities allow CBAM goods to be imported only by an authorised CBAM declarant. The declarant buys its certificates from the competent authority in the EU Member State where it is established. You need the status when your total imports of CBAM goods are more than 50 tonnes per year. For electricity and hydrogen, you need it from the first unit.

An exporter from outside the EU has two options. Its own EU company, such as a Dutch BV, applies for the status itself. Or an indirect customs representative with authorised CBAM declarant status files the declarations, and is then always the declarant. Both options, the apostille for papers from Bahrain and the work of our partners are in our guide for Gulf exporters that need an EU importer.

The first annual declaration is for calendar year 2026. You must submit it by 30 September 2027. From 1 February 2027, you can buy certificates on the common central platform. Since 1 January 2026, EU import declarations have a CBAM code in the additional reference field. All 2027 dates, including the first quarterly certificate check on 31 March 2027, are in our guide to the authorised CBAM declarant for non-EU exporters.

How to handle CBAM with one EU company

Non-ferrous metals were 76.6% of EU imports from Bahrain in 2025, and aluminium is the CBAM good in this group. You need to decide which company has the declarant status for your aluminium shipments when they are imported into the EU. If you sell to European buyers, the buyer has that status and buys the certificates. If you import through your own Dutch BV, your BV has the status and buys the certificates. Your BV can also get the Article 23 licence. The import VAT on every shipment is then declared in the periodic return.

If your smelter has verified low-carbon figures, you can present this advantage yourself as the declarant. If a distributor is the declarant, the distributor decides how the advantage is used in its pricing.

To see what your aluminium costs in certificates each year, with the EU default value or your smelter's verified figures, use the CBAM cost calculator for Bahrain.

Structuring the ownership chain

Bahrain is on the Dutch list of low-tax jurisdictions for 2026. A conditional withholding tax of 25.8% can therefore apply to dividends, interest and royalties that your Dutch company pays to related companies in Bahrain (Belastingdienst, 2026). The Dutch government has said that the tax treaty with Bahrain limits this tax (letter to parliament, 2022). The list for 2026 leaves out the UAE. For owners in Bahrain and the UAE, our team checks the current list first.

The Netherlands and Bahrain have a tax treaty. Design the shareholding chain so that the company that owns the Dutch shares has treaty protection and real substance.

Settle this before the notary drafts the deed, well before the first dividend. We include this in the incorporation process.

Setting up in the Netherlands

A Dutch BV is incorporated by notarial deed and registered with the Chamber of Commerce (KvK). Incorporation is done from abroad by power of attorney, with the parent company holding the shares. After registration, the BV gets its VAT number and its EU customs number (EORI). It then applies for the Article 23 licence and the CBAM authorisation. You can also use the same company for EPR registrations under the Packaging Regulation and for your European contracts.

You can read more about an EU entity for CBAM and fiscal representation and Article 23.

Frequently asked questions

How exposed is Bahrain to CBAM?

In 2025 the EU imported goods worth €1.8 billion from Bahrain. Non-ferrous metals, the product group that includes aluminium, were 76.6% of this (European Commission, 2026). Aluminium is the only non-ferrous metal under the EU carbon border levy (CBAM), and the definitive phase started on 1 January 2026.

Can a Bahraini producer hold authorised CBAM declarant status?

The status is for an importer established in an EU Member State. That importer buys its certificates from the competent authority of the same Member State. A Bahraini producer can get this status through its own company in the EU. An example is a Dutch BV that imports in its own name. An indirect customs representative with the status is the other option. That representative is then always the declarant.

Does the Netherlands have a tax treaty with Bahrain?

Yes, the Netherlands and Bahrain have a tax treaty. Bahrain is also on the Dutch list of low-tax jurisdictions for 2026. A conditional withholding tax of 25.8% can then apply to dividends, interest and royalties paid to related companies in Bahrain, within the limits of the tax treaty. The list for 2026 leaves out the UAE. For owners in Bahrain and the UAE, our team checks the current list first.

What is the benefit of the Article 23 licence for aluminium imports?

Normally you pay import VAT at customs clearance. With the Article 23 licence, you declare it in your periodic VAT return and deduct it in the same return. For large volumes of raw materials, you keep cash in your business on every shipment.