CBAM and Qatar

Qatar makes aluminium and nitrogen fertilisers, two groups of goods under CBAM. CBAM, the Carbon Border Adjustment Mechanism, is the EU's carbon charge at the border. Under CBAM, the importer pays for the emissions from producing the imported goods. EU factories already pay for their own emissions in the same way. Both sectors have been in the definitive phase since 1 January 2026.

Qatari producers work with natural gas. The Qatalum aluminium smelter in Mesaieed has its own gas-fired power plant (Hydro, 2026). QAFCO, also in Mesaieed, was set up to use Qatar's gas reserves and can make 3.8 million tonnes of ammonia and 5.6 million tonnes of urea a year (QAFCO, 2026).

Verified emissions data from your own plant is worth money under CBAM. You get the most from it when you control the import yourself, through your own EU company with authorised declarant status.

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 only allow an authorised CBAM declarant to import CBAM goods. The declarant buys its certificates from the competent authority in the EU Member State where it is established. An importer needs this status when it imports more than 50 tonnes of CBAM goods a year. For electricity and hydrogen, the status is needed 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 legalisation of papers from Qatar and the work of our partners are in our guide for Gulf exporters that need an EU importer.

The first annual declaration covers calendar year 2026 and falls due by 30 September 2027. Certificate sales begin on 1 February 2027 through 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.

The advantage of gas-based production

Under CBAM, the cost of the certificates depends on the embedded emissions of the specific installation. Verified data therefore has a direct value in money. Qatari producers of aluminium and fertilisers use natural gas. With verified figures, your declarant reports the real emissions in place of the default values.

For aluminium, the default values include a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 (Implementing Regulation (EU) 2026/1740). If your own EU company files the declarations, you keep the value of that difference. With an intermediary, your figures are mixed into an average, and you lose the difference.

To put a number on that difference, enter your aluminium tonnes in the CBAM cost calculator for Qatar twice: once with the default value and once with your verified figure.

Benefits of a Dutch entity for Qatari exporters

If you sell through European buyers, you depend on them. They must already have authorised declarant status, and they pass the carbon costs back to you in their price. If you import through your own Dutch BV, you set the terms. Your BV buys certificates directly at the EU carbon price and uses your own verified emissions figures. It invoices European customers as a European supplier under EU VAT rules.

For large volumes of aluminium and fertilisers, the Article 23 licence is very useful. With this licence, your BV declares the import VAT later, in its periodic VAT return. Your company then keeps more cash for every shipment you import through Rotterdam.

Structuring the ownership chain

The Netherlands and Qatar have a double tax treaty. A Gulf group needs to plan its ownership chain before incorporation. We check your planned structure for treaty protection, the Dutch conditional withholding tax rules and real business activity (substance). Your BV can then pay its profits to your group in an efficient way from the date of incorporation.

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 owning the shares. After registration the BV obtains its VAT number and EORI number and applies for the Article 23 licence and the CBAM authorisation. The same BV is then also the base for your European contracts and other EU compliance duties. You can read more about these duties on the EU market entry page.

Further reading: an EU entity for CBAM and fiscal representation and Article 23. For other EU compliance duties, see EU market entry.

Frequently asked questions

Can a Qatari company import CBAM goods into the EU directly?

Only an authorised CBAM declarant may import CBAM goods. The declarant buys its certificates from the competent authority in the EU Member State where it is established. A Qatari company therefore has three options. It can sell to an EU buyer with this status. It can work through an indirect customs representative with authorised CBAM declarant status, who is then always the declarant. It can also set up its own EU company, such as a Dutch BV.

Which Qatari exports fall under CBAM?

CBAM has six sectors in scope. Two of them are aluminium and nitrogen fertilisers, made in Qatar at the Qatalum smelter and by QAFCO in Mesaieed. The other sectors are cement, iron and steel, electricity and hydrogen.

Does the Netherlands have a tax treaty with Qatar?

Yes. The Netherlands and Qatar have a double tax treaty. Before incorporation, you need to plan the ownership chain of your Dutch BV. In this plan, you look at treaty protection, the Dutch conditional withholding tax rules and real business activity (substance).

How fast can a Dutch BV be set up?

A Dutch BV is set up remotely by power of attorney, usually within one week once all documents are complete. After registration the BV obtains its VAT and EORI numbers and applies for the Article 23 licence and the CBAM authorisation.