Industry and commodities · EU importer company

Industrial and commodity exporters, your own EU importer company

An exporter of steel, aluminium, chemicals, fertilisers, energy or agricultural commodities meets the same question at every EU border. Who is the importer, and who answers for the duty, the carbon levy, the chemical registration and the deforestation statement. Customs law requires the importer to be established in the EU, and from 21 September 2027 a customs broker that acts for a company outside the EU counts as the importer itself. The carbon border levy (CBAM) requires an authorised declarant established in the EU, the chemicals regulation an only representative, the energy market rules a representative, and the deforestation rules an operator that first places the goods on the EU market. Exporters with a turnover of EUR 10 to 500 million therefore often want their own Dutch importer company. We set it up and do its administration, and licensed partners do the customs, verification and warehouse work.

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Short answer

Your own Dutch company imports in its own name, with its own customs number (EORI), its own VAT number and its own Article 23 licence that keeps import VAT out of the border. It applies itself for the status of authorised CBAM declarant, for customs simplifications such as the authorised economic operator (AEO) status and for a customs warehouse, and it is the only representative for your chemicals, the representative for your energy trading and the operator for your coffee, cocoa, soy, rubber or wood.

A customs broker that imports for a company outside the EU does so in its own name and is liable for the customs debt jointly and severally with you (Union Customs Code, Articles 18 and 77). From 21 September 2027 such a broker counts as the importer itself (Regulation (EU) 2026/2108, Article 33). Brokers price that risk, ask for securities and keep the right to refuse. Your own company keeps the import, the duty, the levy and the data inside your group.

We set up the company, request its registrations and statuses, keep its books, file its returns and annual accounts and keep the calendar of declarations. Customs brokers, verifiers, fiscal representatives and warehouses from our network do the licensed and physical work, quoted first. You appoint the directors and see every price first.

Want our team to have a look at your situation?

Tell us what you make or sell, where your company is and what you plan in Europe. Our team looks at it and replies with the steps and the dates that apply to you.

Who does what

You own the goods, the plants and the buyers, your Dutch company imports and holds the statuses, and licensed partners do the customs, verification and warehouse work.

You

Your company

  • Production, quality, origin documents and the emissions data of your plants
  • Buyers, prices, volumes and shipping terms
  • The directors of the Dutch company and its business address
We

The Dutch company

  • The Dutch BV as importer and declarant, by power of attorney
  • EORI, VAT, the Article 23 licence, eHerkenning and the application for authorised CBAM declarant status
  • Bookkeeping, VAT returns, annual accounts and the calendar of declarations
Partner from our network

Customs broker, verifier, warehouse, fiscal representative

  • Customs broker for the declarations, AEO and the customs warehouse
  • Verifier for the CBAM emissions data and a chemicals consultant for the REACH file
  • Fiscal representative for group companies that stay abroad
  • Warehouse and bonded storage near Rotterdam and Schiphol

Step by step

From shipments through a broker to shipments in the name of your own EU company.

  1. Your goods and your volumes. You share your products, their customs codes, your volumes and your EU buyers, and we send a written proposal with the roles and the partners.
  2. The company. The notary sets up the Dutch BV by power of attorney.
  3. The numbers. We request EORI, VAT, the Article 23 licence and eHerkenning, and we file the application for authorised CBAM declarant status where your goods need it.
  4. The roles. Your company accepts the mandates as only representative, energy representative or operator, and our partners register and verify where the rules require it.
  5. The first shipment. The customs broker declares in the name of your company, the goods go to the warehouse or the buyer, and the VAT return shows the import under Article 23.
  6. Every quarter and every year. We file the returns, keep the books, prepare the annual accounts and keep the CBAM, REACH and deforestation calendar with you.
50 tonnes
of iron, steel, aluminium, fertilisers or cement a year, above which an importer needs authorised CBAM declarant status before import
1 Feb 2027
from this date CBAM certificates are sold, with the first annual declaration due by 30 September 2027
21 Sep 2027
from this date the new Union Customs Code applies and an indirect customs representative of a company outside the EU counts as the importer

The roles for an exporter of goods, in one table

RoleLawWho can hold itStatus
Importer at customsUnion Customs Code, Regulation (EU) 952/2013, Article 170; from 21 September 2027 Regulation (EU) 2026/2108, Article 27Your Dutch company, or an EU customs broker as indirect representative that is liable with you and from 2027 counts as the importerIn force
Authorised economic operator (AEO)Union Customs Code, Article 39Only a company established in the EU, such as your Dutch companyIn force
Article 23 licence for import VATDutch VAT Act, Article 23Your Dutch company in its own name; a company abroad only through a licensed fiscal representativeIn force
Authorised CBAM declarantRegulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083, Article 5The importer established in an EU country, or its indirect customs representativeDefinitive period since 1 January 2026
Only representative for chemicalsREACH, Regulation (EC) 1907/2006, Article 8A company established in the EU, appointed by the maker outside the EU; it takes over the duties of the importersIn force; the planned revision was dropped on 27 April 2026
Only representative for fluorinated gasesRegulation (EU) 2024/573A company established in the EU that takes full responsibility for compliance and quotaIn force
Representative for wholesale energy tradingREMIT, Regulation (EU) 1227/2011 as amended by Regulation (EU) 2024/1106, Article 9A company established in an EU country where you trade, registered with the national regulatorSince 8 November 2024
Operator for deforestation-free productsEUDR, Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650The company that first places cattle, cocoa, coffee, palm oil, rubber, soy or wood on the EU market, your Dutch company as importerFrom 30 December 2026 for large and medium companies, 30 June 2027 for micro and small ones
Importer of steel under the new quota rulesRegulation (EU) 2026/1384The EU importer, with the duty of 50% on volumes above the quota and the melt-and-pour evidence since 1 October 2026Since 1 July 2026

The rules per role are on our pages importer of record in the EU, authorised CBAM declarant, REACH only representative, energy trading entity and EUDR operator.

Customs, a broker in its own name or your own company

Under the Union Customs Code the declarant for release for free circulation is established in the EU (Article 170). A company outside the EU therefore clears its goods through an indirect customs representative, a broker that declares in its own name on your behalf. The broker is the debtor of the customs debt, and you are a debtor next to it, jointly and severally (Articles 77 and 84). The status of authorised economic operator, with its simplifications and fewer controls, is open to companies established in the EU only.

The new Union Customs Code, Regulation (EU) 2026/2108, applies from 21 September 2027. It keeps the rule that the importer is established in the EU (Article 27) and states that an indirect representative acting for a company outside the EU is considered to be the importer, with all the duties of an importer, including compliance with the product rules that customs enforce at the border (Article 33). From 1 July 2028 only brokers with AEO or Trust and Check status may release goods sold to consumers at a distance. Brokers price that role, ask for securities and keep the right to refuse a shipment.

Your own Dutch company declares in its own name, holds its own EORI number, applies for AEO status and for a customs warehouse where duty and VAT wait until the goods leave for the EU market, and pays the duty once per shipment. With the Article 23 licence in its own name the import VAT is declared and deducted in the same VAT return, so €0 is paid at the border. A company that stays abroad obtains that licence only through a licensed fiscal representative, which is liable with you and asks for a security.

Want our team to have a look at your situation?

Tell us what you make or sell, where your company is and what you plan in Europe. Our team looks at it and replies with the steps and the dates that apply to you.

The carbon border levy

Since 1 January 2026, iron and steel, aluminium, cement and fertilisers above 50 tonnes a year, and hydrogen and electricity from the first unit, may only be imported by an authorised CBAM declarant. The importer established in an EU country applies for the status itself, and where the importer is outside the EU its indirect customs representative must hold it (Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083, Article 5). The declarant buys certificates from 1 February 2027 at the EU carbon price and files the first annual declaration for 2026 by 30 September 2027.

A broker that holds the declarant status for you also holds your emissions data and the obligation to surrender the certificates. Your own Dutch company holds the status itself, applies with its government login (eHerkenning) at the Dutch Emissions Authority (NEa), reports the verified emissions of your own plants and buys the certificates for its own account. The European Commission proposes to extend the levy to about 180 downstream products from 1 January 2028, and the Parliament and the Council are negotiating that proposal in the autumn of 2026. Our CBAM cost calculator shows the cost per shipment.

Chemicals, fluorinated gases and energy trading

A maker of chemicals outside the EU may appoint an only representative established in the EU, which takes over the registration duties of its EU importers under REACH and all other duties of an importer, keeps the records of the quantities imported and the customers, and needs sufficient background in the practical handling of substances (Article 8). The importers in the chain then count as downstream users. The Commission dropped its plan for a full revision of REACH on 27 April 2026, so the only representative rules stand as they are.

For fluorinated gases, a company outside the EU that wants quota or registration in the F-gas portal appoints an only representative established in the EU, which takes full responsibility for compliance with the F-gas regulation and with the REACH registration rules and is liable to penalties for the represented company.

A company outside the EU that trades wholesale gas or electricity in the EU designates, by written mandate, a representative established in an EU country where it trades, registers with that country’s regulator, in the Netherlands the ACM, and the representative is the address for the regulator and the EU agency ACER (REMIT, Article 9, since 8 November 2024). The representative may be any company, so your Dutch company holds that role next to its import role. Europe’s gas benchmark is a Dutch trading point, which is why many traders choose the Netherlands.

Coffee, cocoa, soy, rubber and wood

From 30 December 2026 the deforestation regulation applies to large and medium companies, and from 30 June 2027 to micro and small ones. The operator that first places cattle, cocoa, coffee, palm oil, rubber, soy or wood on the EU market files the due diligence statement, and downstream operators and traders rely on its reference number. For an exporter outside the EU, its EU importer is that operator. A fine for a legal person must be able to reach at least 4% of its EU-wide turnover (Article 25).

Your own Dutch company is that operator, files the statements in the EU information system with the geolocation data of your plots, and keeps the records for five years. A buyer that imports your goods itself takes that duty and that fine exposure on, and many buyers prefer a supplier with its own EU operator company. The country pages for Brazil, Côte d’Ivoire, Ghana, Vietnam and Indonesia are on our page EUDR operator.

Service providers or your own company

 A broker, a fiscal representative and an only representativeYour own Dutch company
Who is the importer and the declarantThe broker, in its own name, liable with you and from 21 September 2027 the importer itselfYour Dutch company
Who holds the CBAM status and the emissions dataThe brokerYour Dutch company
Import VAT at the border€0 through the fiscal representative, against a security and its fee€0 with the Article 23 licence in the name of your company
Who keeps the records and the calendarEach provider, within its own mandateYour company, with our administration and the partners you contract
SuitsOccasional shipments, one role, a market testRegular shipments, several roles in one company of your own

The whole set-up is on the page your own EU company with a partner that stays.

Why a partner that stays

An importer of goods lives by its calendar. Customs declarations per shipment, the quarterly VAT return with the Article 23 entries, the CBAM declaration by 30 September with verified data, the REACH records, the energy trading reports and the deforestation statements all have dates, and a missed date costs duty, interest, a fine or a shipment at the border. We keep the books, file the returns and the annual accounts, maintain the licences and the statuses, and keep the calendar with your customs broker and your verifier, with a reminder to your board when a date comes up. Your board decides on prices, buyers and volumes.

The dates for exporters of goods

DateWhat applies
1 January 2026Definitive CBAM period, with authorised declarant status above 50 tonnes a year, and from the first unit for hydrogen and electricity
1 May 2026The EU-Mercosur interim trade agreement applies, and the EU importer claims the lower duty with the statement on origin of the exporter
1 July 2026The new EU steel import rules apply, with a duty of 50% above the quota (Regulation (EU) 2026/1384), and melt-and-pour evidence since 1 October 2026
30 December 2026The deforestation regulation applies to large and medium companies
1 February 2027Sale of CBAM certificates starts
30 June 2027The deforestation regulation applies to micro and small companies
21 September 2027The new Union Customs Code applies, with the importer established in the EU or represented by a broker that counts as the importer
30 September 2027First annual CBAM declaration, for 2026, with the surrender of certificates
1 January 2028Proposed start of the CBAM extension to downstream products, under negotiation in the autumn of 2026
1 July 2028Single VAT registration in the EU under the VAT in the digital age package, and the distance-sales rules of the new customs code

All dates per rule, with their sources, are in our EU compliance calendar.

Sources: Regulation (EU) 952/2013, Articles 18, 39, 77, 84 and 170; Regulation (EU) 2026/2108, Articles 27, 33 and 287, and Council press release of 3 September 2026; Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083, Article 5, and the European Commission on the customs reform; Regulation (EC) 1907/2006, Article 8 and Council document 10294/26 on the dropped revision; Regulation (EU) 2024/573 and the F-gas Portal; Regulation (EU) 1227/2011, Article 9, as amended by Regulation (EU) 2024/1106, and the third open letter of ACER; Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, Articles 4 and 25; Regulation (EU) 2026/1384; Decree on fiscal representation, Government Gazette 2022, 32161. Checked on 29 October 2026.

Common questions

Can our customs broker stay the importer? +
Yes, as indirect representative in its own name, liable for the customs debt with you, and from 21 September 2027 as the importer itself with all the duties of an importer. Your own Dutch company takes that role in its own name and keeps the duty, the data and the statuses inside your group.
Who holds the CBAM declarant status, the broker or our company? +
The importer established in an EU country applies itself. Where the importer is outside the EU, its indirect customs representative must hold the status. Your Dutch company holds it in its own name and buys the certificates for its own account.
Do we still need a fiscal representative? +
Your Dutch company registers for VAT and holds the Article 23 licence in its own name, so a fiscal representative is unnecessary for it. A group company that stays abroad and imports in its own name uses a licensed fiscal representative from our network.
Who verifies the emissions data for CBAM? +
An accredited verifier from our network checks the emissions data of your plants, and your Dutch company reports the verified figures in its annual CBAM declaration by 30 September.
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