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 goods | CBAM status needed | Good to know |
|---|---|---|
| Fertilisers, ammonia included | Above 50 tonnes a year | Ammonia counts as a fertiliser good under CBAM, with customs code 2814. |
| Aluminium | Above 50 tonnes a year | The list goes by customs code (CN code) and also covers some aluminium products. |
| Iron and steel, cement | Above 50 tonnes a year | The 50 tonnes count fertilisers, aluminium, iron and steel and cement together, per importer and per calendar year. |
| Hydrogen | From the first kilogram | A certificate shows whether it counts as renewable or low-carbon. |
| Petrochemicals, such as plastics and methanol | Outside CBAM in 2026 | Your 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 company | Option 2: an indirect customs representative | |
|---|---|---|
| The declarant | Your Dutch company (BV), as the importer | The representative, in every case |
| Who applies for the status | Your Dutch company, in the EU CBAM registry | The representative, for its own status |
| What you get | Your own emissions data, prices and EU customers, and one company for VAT, customs and stock | A partner with the status files the declarations for your shipments |
| Good choice when | You ship every year, or sell from stock in the EU | You 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
| Date | What happens |
|---|---|
| 1 February 2027 | Certificate sales start. Your company buys the certificates for its 2026 imports. |
| 31 March 2027 | First quarterly check: certificates on your company’s CBAM account for at least 50% of the emissions in its 2027 imports so far. |
| 30 September 2027 | First 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.
| Country | Apostille or legalisation |
|---|---|
| Saudi Arabia | Apostille, since 7 December 2022 |
| Oman | Apostille, since 30 January 2012 |
| Bahrain | Apostille, since 31 December 2013 |
| United Arab Emirates | Legalisation: the Ministry of Foreign Affairs of the UAE, then the Dutch consulate-general in Dubai |
| Qatar | Legalisation: the Qatari Ministry of Foreign Affairs, then the Dutch embassy in Doha |
| Kuwait | Legalisation: 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
- Your Dutch company. A BV, or a holding with an operating company, set up by the notary with your power of attorney. See company formation in the Netherlands.
- Your VAT number and your EU customs number (EORI number). See Dutch VAT registration and the EORI number.
- The licence to report import VAT in your VAT return (Article 23 licence). Your company applies itself, as a company established in the Netherlands. It reports the import VAT in its VAT return and deducts it in the same return, so it keeps its cash. See the Article 23 licence.
- eHerkenning level 3, the Dutch business login, also for a director abroad. See eHerkenning for foreign directors.
- The CBAM application of your company in the EU CBAM registry, up to the decision of the NEa.
- The bank file. The documents and the ownership chart your bank asks for. A BV must have a business bank account. The bank decides, and approval often takes 2 to 8 weeks. See opening a business bank account.
- The yearly declaration planning. The CBAM declaration by 30 September, the dates for your certificate purchases and the quarterly checks, with your customs broker and your emissions verifier.
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.
- Customs broker: the import declarations, and the indirect representation when you choose option 2.
- Accredited emissions verifier: checks the emissions data of your plant under the EU verification rules.
- Certifier: the audit for renewable or low-carbon hydrogen and ammonia.
- Only representative for chemicals (REACH): your producer outside the EU can appoint one for the registration duties of importers. See the REACH only representative.
- Terminals and transport: tank storage, warehouses and shipping, with selected partners near Schiphol and Rotterdam.
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
- Saudi Arabia: fertilisers, aluminium, steel and cement
- United Arab Emirates: aluminium and steel
- Qatar: aluminium and nitrogen fertilisers
- Oman: aluminium, steel and green hydrogen
- Bahrain: aluminium
How it works, step by step
- 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.
- Documents. Our team sends the list of papers for your country, with the steps for the apostille or legalisation.
- 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.
- Numbers and login. The VAT number, the EORI number, the Article 23 licence and eHerkenning level 3.
- CBAM application. Your company applies in the EU CBAM registry, and the NEa decides.
- Partners. After you ask, our team selects a customs broker, an accredited verifier and other partners for your goods. You see every price first.
- Bank file. Our team prepares the file for your bank. The bank decides.
- Every year. The planning for your certificate purchases, the quarterly checks and the CBAM declaration by 30 September.
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.
- Business bank account: the complete file your bank asks for
- eHerkenning: your login for the Dutch tax portal
- EORI number: your number for import and export
- Article 23 licence: you settle import VAT in your VAT return, so you keep that cash in your company
- One VAT return for all your online sales in the EU (One Stop Shop, OSS)
- Payroll tax number, so your company can pay you a salary
- A lower director salary, prepared and submitted to the tax authority
- The 30% ruling for you or your staff, when you relocate to the Netherlands
- Bookkeeping, VAT returns and annual accounts
- Licences and EU rules for your sector
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