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CBAM importer obligations in the Netherlands: what you need to do, who you report to, and when

If your company is established in the Netherlands, your national competent authority for CBAM is the Nederlandse Emissieautoriteit (NEa). Rotterdam is Europe's largest port and the primary entry point for CBAM goods into the EU. Before importing CBAM goods from 1 January 2026, you must apply for authorisation through the EU CBAM Registry (Art. 5). CBAMCheck generates 12 structured documents that prepare your data before you interact with the Registry — ready for NEa oversight.

Generate your CBAM dossier — €299Free check: does CBAM affect you?

€299 · One-time · 12 professional deliverables · Your data never leaves your browser

Built on Reg. (EU) 2023/956 · Modified by Reg. (EU) 2025/2083 · 13,566 default values (Reg. 2025/2621) · 100% browser-side — your data never leaves your device

The numbers that matter for CBAM importers in the Netherlands

NEa
Nederlandse Emissieautoriteit — your NCA for CBAM (Art. 17)
30 Sept 2027
First annual CBAM declaration deadline (Art. 6) for CY 2026
#1 port
Rotterdam is the largest port in Europe and the main entry point for CBAM goods

Your step-by-step CBAM compliance timeline as a Dutch importer

1
Apply for authorisation as CBAM declarant
Art. 5. Submit your application through the EU CBAM Registry. The NEa reviews and authorises declarants established in the Netherlands.
2
Identify all CBAM goods in your import portfolio
Check your CN codes against Annex I. Steel, aluminium, cement, fertilisers, hydrogen and electricity are covered. De minimis: 50 tonnes/year (Art. 2a).
3
Collect emissions data from your suppliers
Request actual emissions data from third-country suppliers. Default values from Reg. 2025/2621 apply if actual data is unavailable — with a 10% mark-up.
4
Purchase CBAM certificates quarterly
Art. 22(2): hold certificates covering ≥50% of embedded emissions at end of each quarter. Price mirrors EU ETS auction (Art. 21).
5
Submit your annual CBAM declaration by 30 September
Art. 6: first declaration due 30 September 2027 for CY 2026. Quantities, emissions, certificates, carbon price deductions.
6
Undergo verification by an accredited verifier
Art. 8 + Annex VI: embedded emissions must be verified. CBAMCheck includes verification preparation documentation.

Three compliance mistakes Dutch importers should avoid

MISTAKE 1 — ASSUMING TRANSIT GOODS ARE EXEMPT

Not distinguishing transit through Rotterdam from import into the EU

CBAM applies to goods released for free circulation in the EU customs territory. Goods transiting through Rotterdam to a non-EU destination are not CBAM goods. But if your company is the importer of record, CBAM obligations fall on you — regardless of which EU port the goods enter through.

MISTAKE 2 — LATE AUTHORISATION

Waiting until shipments arrive to apply for declarant status

Art. 5 requires authorisation before importing CBAM goods. Given the volume of CBAM goods passing through Rotterdam, early application to the NEa is essential to avoid disruption.

MISTAKE 3 — MISSING QUARTERLY CERTIFICATE OBLIGATIONS

Treating CBAM as an annual-only obligation

Art. 22(2) requires quarterly certificate purchases covering ≥50% of embedded emissions. Missing quarterly thresholds creates compliance exposure throughout the year.

What you receive: 12 deliverables in one ZIP file

CBAMCheck generates a complete CBAM compliance dossier — not a single PDF. 12 structured documents delivered as a ZIP file, each citing the specific article of Reg. (EU) 2023/956 it addresses.

1

Scope Assessment

Determines whether your imports fall under CBAM and which obligations apply. Art. 2 + Art. 2a of Reg. (EU) 2023/956.

2

Embedded Emissions Calculation

Calculates embedded emissions per tonne using default values from Implementing Reg. (EU) 2025/2621 or your actual data. Art. 7 + Annex IV.

3

CBAM Certificate Estimation

Estimates the number of certificates required and the projected cost, adjusted for free allocation (Art. 31).

4

Draft CBAM Declaration

Pre-structured declaration following Art. 6(2) requirements: quantities, emissions, certificates, carbon price.

5

Carbon Price Documentation

Documents any carbon price paid in the country of origin for Art. 9 deduction. Pre-formatted for the CBAM Registry.

6

Annex V Record Template

Record-keeping template compliant with Annex V requirements. Ready for verifier review.

7

Verification Preparation

Structured preparation for Art. 8 verification by an accredited verifier. Annex VI checklist included.

8

Supplier Letter Template

Model letter in English requesting emissions data and installation information from your third-country supplier.

9

Compliance Calendar (.ics)

Importable calendar with quarterly certificate obligations (Art. 22(2)), annual declaration deadline (30 September), and key milestones.

10

Executive Summary

One-page overview of your CBAM exposure: cost estimate, timeline, risk areas. Ready for management or board reporting.

11

Interactive HTML Dashboard

Standalone HTML dashboard with 2026–2032 projections reflecting free allocation phase-out (Art. 31). Works offline, no subscription.

12

Compliance Calendar Document

Visual calendar of all CBAM deadlines, reporting windows and certificate purchase schedules.

Generated from your input data, in your browser. No data leaves your device.

See what you get

Download a sample CBAMCheck dossier. This is a real output generated with generic data — the same 12 deliverables you will receive with your company's actual figures.

Download sample dossier (ZIP)

Generic data. Your dossier will contain your actual import figures, CN codes and emissions calculations.

Estimate your CBAM exposure

Select your sector and country of origin. CBAMCheck searches through 13,566 official records from Implementing Reg. (EU) 2025/2621 and shows the result with the 2026 mark-up included.

Quick CBAM Calculator

Average European Commission default values per sector and country of origin.

Default emissions (tCO₂e/t)
Mark-up 2026 (10%)
Total emissions with mark-up
CBAM rate 2026 (2.5%)
Estimated certificates

This is a quick estimate. Your complete dossier includes projections through 2032, an editable interactive dashboard, and 10 PDF documents.

Generate your complete dossier — €299 →

Average values per sector from Implementing Reg. (EU) 2025/2621. The complete dossier uses the exact CN code of your goods, not the sector average. Estimated EU ETS price: €75/tCO₂e.

What CBAM compliance costs with each alternative

FeatureFree toolCBAMCheckSaaS Enterprise
PriceFree€299 (one-time)€1,990–€4,800/year
ModelGeneric template12 professional deliverablesAnnual subscription
Default valuesNot included13,566 (Reg. 2025/2621)Partial
Interactive dashboardNoHTML, 7-year projectionPlatform-locked
Supplier letterNoEnglish template includedVariable
Art. 8 verification prepNoIncludedVariable
PrivacyVariable100% browser-sideData on server
Multi-company supportNoVia Professional PackYes

Choose your licence

1 DOSSIER
€299
/ dossier

  • 10 professional PDF documents
  • Interactive HTML dashboard (2026–2032 projection)
  • 13,566 official default values integrated
  • English supplier letter template
  • Importable .ics calendar
  • 10 regenerations · 30 days
  • 1 licence = 1 importing company
Get your individual licence →
PROFESSIONAL PACK
€1,999
70 generations · 1 key

  • 70 generations with a single key
  • 70 complete dossiers (12 deliverables each)
  • Switch product between generations
  • Ideal for customs brokers
  • For consultants billing CBAM compliance
70 interactive HTML Dashboards × product (projection 2026–2032). Real-time tables and charts with variable calculations. No technical training required. Fully intuitive.
🔒 Data stays on your computer. No information shared with third parties.
Request Professional Pack →

How your licence works

1
1 licence = 1 importing company. You pay €299 for the dossier you generate now. The licence is linked to your company name + EORI.
2
Up to 10 regenerations of the ZIP to correct data, adjust goods or update technical information.
3
30-day editing window from first activation. Within that period you can regenerate the dossier as many times as needed (up to 10).
4
The downloaded dossier is yours forever. It does not expire and is not tied to any subscription. The 10 PDFs, HTML dashboard and .ics calendar remain functional offline.

The EU CBAM portal ASKS for data. CBAMCheck CALCULATES it.

THE EU CBAM PORTAL

Asks you to declare data

The EU CBAM Registry (Art. 14) requires you to submit total embedded emissions, number of certificates and carbon price documentation. It does not calculate these for you. You must arrive with the numbers ready.

CBAMCHECK

Calculates the data you need to declare

CBAMCheck takes your import data (tonnes, CN codes, country of origin) and generates the embedded emissions calculation, certificate estimation, carbon price documentation and all supporting records. You download the dossier and use it to complete your declaration in the CBAM Registry.

Enforcement: what happens when CBAM certificates are missing

Art. 26 of Reg. (EU) 2023/956 sets the penalties.

⚠️
Authorised declarant: penalty identical to EU ETS rate
EU ETS rate per certificate

Art. 26(1): an authorised CBAM declarant who fails to surrender the required certificates by 30 September faces a penalty identical to the excess emissions penalty under Art. 16(3) of Directive 2003/87/EC, increased per Art. 16(4). The penalty applies per certificate not surrendered. Payment does not release the obligation to surrender outstanding certificates (Art. 26(3)).

⚠️
Unauthorised importer: penalty 3–5 times the standard rate
3–5×

Art. 26(2): anyone introducing goods without authorisation faces a penalty of 3 to 5 times the standard penalty, depending on duration, gravity, scope, intent and cooperation. Also applies to importers exceeding the de minimis threshold (50 tonnes, Art. 2a) without authorisation (Art. 26(2a)).

Importing CBAM goods through Rotterdam from multiple third-country origins?

The Professional Pack covers 70 dossier generations. One key for 70 complete dossiers — compare costs across origins, switch between companies.

Request Professional Pack →
70 generations · 1 key · Ideal for customs brokers and freight forwarders in the Netherlands

What CBAMCheck guarantees and what it does not

CBAMCheck generates a document structured according to Art. 6 and Art. 7 + Annex IV of Regulation (EU) 2023/956 from the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as importer or authorised CBAM declarant.

We guarantee that the document structure follows Regulation (EU) 2023/956 and that the legal references cited are correct. We do not guarantee that a specific document will be accepted by a national competent authority in a specific case.

CBAMCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions

Is this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The downloaded dossier is yours forever.
Can I request a refund?
By activating the licence you give express consent for the immediate generation of digital content under Art. 16(m) of Directive (EU) 2011/83, waiving the 14-day withdrawal right. Refunds are accepted only for reproducible technical faults.
What if the regulation changes?
If the regulation changes during your licence validity, you can regenerate the document with the updated version of the generator at no extra cost.
Who is the NCA for CBAM in the Netherlands?
The national competent authority for CBAM in the Netherlands is the Nederlandse Emissieautoriteit (NEa), the same body that oversees the EU ETS in the country. The NEa reviews authorisation applications and supervises CBAM compliance for importers established in the Netherlands, as designated under Art. 17.
Does importing through Rotterdam create special CBAM obligations?
CBAM obligations attach to the importer of record — the company releasing goods for free circulation — not to the port of entry. If your company is established in the Netherlands and is the importer of record, you report to the NEa regardless of which port the goods physically enter through.
Does CBAMCheck prepare documentation for the NEa?
CBAMCheck generates 12 structured documents based on Reg. (EU) 2023/956. The dossier is designed to prepare your emissions data, certificate estimates and verification documentation before you submit through the CBAM Registry under NEa oversight.
⚠️ Important notice: CBAMCheck is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. CBAMCheck does not replace a qualified professional assessment.

Rotterdam handles more CBAM goods than any other EU port. Prepare your documentation before the NEa asks for it.

12 deliverables. Emissions calculation. Certificate estimation. Art. 8 verification prep. Reg. (EU) 2023/956. €299.

€299 one-time
12 professional deliverables · Browser-side · No subscription · Reg. (EU) 2023/956
Generate your CBAM dossier — €299