Gulf exporters · EU importer · CBAM

EU importer for Gulf exporters: your Dutch company and CBAM status

Exporters of fertilisers, ammonia, aluminium and petrochemicals from Saudi Arabia, the UAE, Qatar, Kuwait, Oman and Bahrain sell to Europe through an importer in the EU. Hydrogen exporters follow later. Your own Dutch company can be that importer, with its own status under the EU carbon border tax (CBAM). We help you set up that company, apply for its status and plan how profit goes back to the Gulf at the lowest possible tax cost.

Short answerThree Gulf exports fall under the EU carbon border tax (CBAM): fertilisers (ammonia included), aluminium and hydrogen. The importer in the EU needs the status of authorised CBAM declarant before the first import: for hydrogen from the first kilogram, for the other CBAM goods above 50 tonnes a year. A Gulf exporter has two options. Its own Dutch company applies for the status itself, with eHerkenning level 3, and the Dutch Emissions Authority (NEa) decides. Or an indirect customs representative with the status files the declarations and is then always the declarant. Certificate sales start on 1 February 2027. The first annual declaration, for 2026 imports, is due by 30 September 2027.
Last reviewed: October 2026

Why fertiliser, ammonia and aluminium exports to Europe need an EU importer

Goods under the EU carbon border tax (CBAM) need an importer with the status of authorised CBAM declarant. Above the threshold, customs lets only an authorised CBAM declarant import these goods (CBAM Regulation, Article 25). The status comes first, the shipment second.

Your goodsCBAM status neededGood to know
Fertilisers, ammonia includedAbove 50 tonnes a yearAmmonia counts as a fertiliser good under CBAM, with customs code 2814.
AluminiumAbove 50 tonnes a yearThe list goes by customs code (CN code) and also covers some aluminium products.
Iron and steel, cementAbove 50 tonnes a yearThe 50 tonnes count fertilisers, aluminium, iron and steel and cement together, per importer and per calendar year.
HydrogenFrom the first kilogramA certificate shows whether it counts as renewable or low-carbon.
Petrochemicals, such as plastics and methanolOutside CBAM in 2026Your importer still handles VAT and customs. Many chemical substances need a registration under the EU chemicals rules (REACH) from 1 tonne a year.

Who imports depends on your sales terms. When your EU buyer imports the goods, your buyer needs the status and buys the certificates. When you sell delivered duty paid (DDP), or sell from your own stock in a tank or warehouse in the EU, your side handles the import. Your Dutch company can then be the EU importer of record for ammonia, fertiliser and aluminium from your own plants.

Rotterdam is the largest port in Europe, with 428.4 million tonnes in 2025. Your Dutch company can sell from stock there to buyers across the EU.

Two ways to get CBAM declarant status in the Netherlands

Option 1: your own Dutch companyOption 2: an indirect customs representative
The declarantYour Dutch company (BV), as the importerThe representative, in every case
Who applies for the statusYour Dutch company, in the EU CBAM registryThe representative, for its own status
What you getYour own emissions data, prices and EU customers, and one company for VAT, customs and stockA partner with the status files the declarations for your shipments
Good choice whenYou ship every year, or sell from stock in the EUYou test the market or ship a few times a year

Option 1: your own Dutch company applies

Your Dutch limited company (a BV) is established in the EU, so it applies for the status itself. The application goes through the EU CBAM registry. In the Netherlands, it needs eHerkenning level 3, the Dutch business login for government portals. The Dutch Emissions Authority (NEa) decides on the application.

Your company then files its own yearly CBAM declaration. Your company also buys its own CBAM certificates. Our team plans the purchases and the dates with you.

Option 2: an indirect customs representative

When your company outside the EU stays the importer, it works through an indirect customs representative. That representative is then always the declarant. It needs authorised CBAM declarant status itself, also for imports below 50 tonnes.

After you ask, our team selects a customs broker with this status and checks the status before the quote goes to you. You see the price first.

All CBAM rules for importers from outside the EU are in our guide to the authorised CBAM declarant. For your own company as importer of all your goods, see importer of record in the EU.

The 2027 dates for CBAM

DateWhat happens
1 February 2027Certificate sales start. Your company buys the certificates for its 2026 imports.
31 March 2027First quarterly check: certificates on your company’s CBAM account for at least 50% of the emissions in its 2027 imports so far.
30 September 2027First annual CBAM declaration, for 2026 imports, and surrender of the certificates. The same deadline applies every year after.

One certificate covers one tonne of CO2. For 2026 imports, the price is the quarterly average of EU emissions trading prices: €75.36 for the first quarter of 2026, €75.28 for the second and €82.32 for the third, published on 5 October 2026.

EU plants still get part of their emission allowances for free, and the number of certificates is reduced in the same way. This reduction becomes smaller every year until 2034 (European Commission, Guidance No. 4, 14 August 2026).

For your own fertiliser or aluminium tonnes, choose your Gulf country in the CBAM cost calculator and see the certificate cost for each year up to 2034.

Documents for your Dutch company from Saudi Arabia, the UAE, Qatar, Kuwait, Oman and Bahrain

The notary in the Netherlands needs official papers from your country, such as the extract from your company register and your power of attorney for the deed. Each paper needs an apostille or a legalisation, depending on the country.

CountryApostille or legalisation
Saudi ArabiaApostille, since 7 December 2022
OmanApostille, since 30 January 2012
BahrainApostille, since 31 December 2013
United Arab EmiratesLegalisation: the Ministry of Foreign Affairs of the UAE, then the Dutch consulate-general in Dubai
QatarLegalisation: the Qatari Ministry of Foreign Affairs, then the Dutch embassy in Doha
KuwaitLegalisation: the Kuwaiti Ministry of Foreign Affairs, then the Dutch embassy in Kuwait City

An apostille is one certificate from an authority in your country. Legalisation takes two steps, so plan extra time for papers from the UAE, Qatar and Kuwait. Papers in English can be used as they are. Papers in Arabic need a sworn translation into Dutch, English, French or German (Netherlands Worldwide, 2026).

Our team sends you the list of papers and the steps for your country.

Your Dutch company is usually set up within one week once all documents are complete.

What we arrange, and what partners do

Doing business in or from the Netherlands, with Europe or the rest of the world? You get more than a Dutch company. You get the right structure to grow your business and your wealth, with the lowest possible tax burden. Our team works from Hoofddorp, next to Schiphol.

What we arrange ourselves

Partners do the specialist work

After you ask, our team chooses partners for your products and volumes. The team checks each partner’s licence or status before you receive a price. You decide. The partner invoices your company for its own work, and we invoice our own work.

More about this way of working: how we work with partners.

Renewable and low-carbon hydrogen: certification

Hydrogen and ammonia sold as renewable fuel of non-biological origin (RFNBO) need a certificate under a scheme recognised by the European Commission. These schemes are ISCC EU, REDcert for countries with a REDcert country profile, and CertifHy, worldwide and for renewable fuel only.

Hydrogen from natural gas counts as low-carbon only from 70% fewer emissions than the fossil comparator, the fossil fuel it replaces. This rule has been in force since 11 December 2025 (Delegated Regulation (EU) 2025/2359).

NEOM in Saudi Arabia is built to convert up to 600 tonnes of hydrogen a day into ammonia for export, with the first green ammonia expected in 2027 (NEOM Green Hydrogen Company, 2026). For CBAM, certification and imports of hydrogen and ammonia, see hydrogen and ammonia imports into the EU.

Smaller hydrogen companies, equipment suppliers and service firms: see hydrogen companies in the Netherlands.

Who owns your Dutch company

Your company in the Gulf can own the Dutch company directly, or through a Dutch holding for your European companies and property. See the Dutch holding for Gulf owners. For 2026, the Dutch list of low-tax jurisdictions names Bahrain and leaves out the UAE. For owners in Bahrain and the UAE, our team checks the current list first.

All six Gulf states are outside the EU list of high-risk countries for money laundering (European Commission, January 2026). A complete bank file with your ownership chart, the source of your funds and your contracts helps your bank decide.

CBAM guides per Gulf country

How it works, step by step

  1. Free first advice. You tell us your goods, the tonnes a year, the EU countries of your buyers and your sales terms. Our team answers in writing which option suits your company.
  2. Documents. Our team sends the list of papers for your country, with the steps for the apostille or legalisation.
  3. Your Dutch company. You sign a power of attorney for the deed in your own country, and the notary in the Netherlands signs the deed.
  4. Numbers and login. The VAT number, the EORI number, the Article 23 licence and eHerkenning level 3.
  5. CBAM application. Your company applies in the EU CBAM registry, and the NEa decides.
  6. Partners. After you ask, our team selects a customs broker, an accredited verifier and other partners for your goods. You see every price first.
  7. Bank file. Our team prepares the file for your bank. The bank decides.
  8. Every year. The planning for your certificate purchases, the quarterly checks and the CBAM declaration by 30 September.

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Company formation

Your company in the Netherlands

One package for the full setup. You sign a power of attorney in your own country. The notary in the Netherlands does the rest.

Swipe to see all four options →

Your Dutch BV

from €2,950

excl. VAT

  • The notary deed, signed for you with a power of attorney
  • Registration at the Dutch Chamber of Commerce (KVK)
  • The identity check the law requires
  • Registration of the owners in the register of ultimate owners (UBO register)
  • Your tax number and VAT number
  • The list of documents from your country, and how to legalise them (apostille)
  • Advice on the setup that keeps your tax low from year one: one company or a holding, your first financial year and your salary
  • Personal support during the setup and the start of your company

Holding and operating company

from €4,950

excl. VAT

Set up for growth of your company and your wealth.

  • Two companies, set up together, with everything from the BV package for both
  • You can pay profit to your holding tax-free (participation exemption)
  • In your holding, you keep your profit apart from the risks of daily business, and you can invest it
  • If you sell your operating company later, your holding receives the profit tax-free

What you can add

Made for your company. The price is in your proposal.

Your first-year plan

Before you start trading, the team looks at everything you plan to do. You get a written plan, and the applications are filed for you. See the first-year plan →

  • The registrations and licences your company needs
  • Your salary, dividend and loans from your company in year one
  • The tax schemes and deductions you are entitled to
  • Your numbers for the first year: tax, salary and what you keep in your company

Your written proposal shows the exact amount before you decide. Owners from some countries need extra checks.

Want our team to have a look? →Free advice on your next step

Frequently asked questions

Is ammonia covered by CBAM?
Yes. Ammonia counts as a fertiliser good under the EU carbon border tax (CBAM), with customs code 2814. When your importer brings in more than 50 tonnes of CBAM goods a year, it needs authorised CBAM declarant status before the import.
Can a Saudi exporter use a Dutch company as its EU importer?
Yes. A Saudi company can own a Dutch company (BV). The BV is established in the EU, so it can import in its own name and apply for authorised CBAM declarant status itself. Papers from Saudi Arabia need an apostille, possible since 7 December 2022.
Who is the CBAM declarant when we use an indirect customs representative?
The representative. When the importer is established outside the EU, the indirect customs representative is always the declarant. The representative needs authorised CBAM declarant status itself, also for imports below 50 tonnes.
How does a Dutch company become an authorised CBAM declarant?
Your Dutch company applies in the EU CBAM registry. In the Netherlands, the application needs eHerkenning level 3, the Dutch business login. The Dutch Emissions Authority (NEa) decides. Our team prepares the application with your company.
Does a small hydrogen shipment need CBAM status?
Yes. Hydrogen counts from the first kilogram, so the importer needs the status before the first shipment, also for a test shipment. For fertilisers and aluminium, the status is needed above 50 tonnes a year.
Who buys the CBAM certificates?
The authorised CBAM declarant. With your own Dutch company as declarant, your company buys its own certificates, from 1 February 2027. For 2026 imports, the price is the quarterly average of EU emissions trading prices: €75.36 per tonne of CO2 for the first quarter of 2026 and €82.32 for the third quarter.
Which documents do we need from the UAE, Qatar or Kuwait?
Official papers from the UAE, Qatar and Kuwait need legalisation in two steps: first the foreign ministry of the country, then the Dutch embassy or consulate-general. Papers from Saudi Arabia, Oman and Bahrain need an apostille. Papers in Arabic also need a sworn translation. Our team sends you the list for your country before the notary starts.
Are petrochemicals covered by CBAM?
Petrochemicals such as plastics and methanol are outside the six CBAM groups in 2026. Your importer still needs a VAT number and an EU customs number (EORI number). Many chemical substances also need a registration under the EU chemicals rules (REACH) from 1 tonne a year.
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