Carbon Border Adjustment Mechanism (CBAM)

Since 1 October 2023, the Carbon Border Adjustment Mechanism (CBAM) has been gradually introduced. The CBAM is a European regulation. The EU uses it to correct CO2 emissions from the production of certain goods outside the EU at the border. Customs and the Dutch Emissions Authority enforce this regulation. We understand that these changes may raise questions. That is why we have gathered the latest information about the CBAM on this page.

For specific questions about the CBAM, we have prepared a list of questions and answers about the CBAM registry. Below, you will also find a link to the CBAM registry and a link to the website of the Dutch Emissions Authority. There, you can also find information and frequently asked questions and answers about the CBAM.

Access the CBAM registry of the European Commission
Access the CBAM website of the Dutch Emissions Authority

What is CBAM?

The CBAM is a carbon adjustment upon import into the EU of designated goods, based on the CO2 emissions in the production process outside the EU. The aim of CBAM is to prevent the risk of carbon leakage. Also, by encouraging the reduction of emissions by operators in third countries (countries outside the EU), global carbon emissions should be reduced.


CBAM is an EU regulation and part of the 'Fit for 55' package. The goal of this package is to reduce greenhouse gas emissions in the EU by at least 55% by 2030.

Currently, the EU operates a system where producers within the EU have to purchase emission allowances for the CO2 emissions of their products (EU Emissions Trading System, EU ETS). The CBAM price adjustment ensures that these producers no longer face a competitive disadvantage when importing from third countries with lower climate standards.

To whom does CBAM apply?

CBAM applies to importers of CBAM goods. These are goods in the categories: iron and steel, cement, fertilisers, aluminium, electricity and hydrogen. You can access the list of CBAM goods by searching 'CBAM' on

The regulation states that the "importer" means either the person lodging a customs declaration for release for free circulation of goods in their own name and on their own behalf or, where the customs declaration is lodged by an indirect customs representative in accordance with Article 18 of Regulation (EU) No 952/2013, the person on whose behalf such a declaration is lodged.

This may involve the following situations:

  • If you make your own declarations then you are considered the importer and the obligations under the regulation apply to you.
  • If you use direct representation you are regarded as the importer and the obligations under the regulation apply to you and not to your direct representative.
  • If you use indirect representation then you have a choice: you must make arrangements with your indirect representative as to who acts as the importer within the meaning of the regulation and thus who must comply with the obligations of the regulation.
  • If you not established in the EU then only an indirect representative can act for you as importer of CBAM goods and fulfil the obligations of the regulation for you. You make arrangements in this regard with your indirect representative.

What phases are involved in the implementation of CBAM?

The implementation consists of 2 phases:

  • The transitional phase (from 1 October 2023 to 31 December 2025)
  • Full implementation (from 1 January 2026 onwards)

What changed since 1 October 2023?

Reporting requirements

Since 1 October 2023, the reporting obligation for CBAM goods applies. As an importer, you are required tp submit a report to the European Commission within 1 month following the conclusion of each quarter. In this report, you state the quantity of CBAM goods you have imported and the amount of CO2 emitted during the production of those goods.

The next report concerns the second quarter of 2024. You must submit this report no later than 31 July 2024. On 17 August 2023, the EC published the implementing regulation for the CBAM transition period. In the annexes to this implementing regulation, you will find the requirements that the quarterly reporting must meet and how you must report CO2 emissions released during production.

You submit the quarterly reports to the European Commission through the CBAM Transitional Registry. More information about using the CBAM Transitional Registry is available on the European Commission's website. On the NEa website, you can find more information about the content and submission of the quarterly reports. To log in to the registry, you register with eHerkenning. Learn more about logging in to the CBAM registry on the Login Instruction CBAM registry page (only available in Dutch).

Mandatory reporting

Since 1 October 2023, Customs must inform importers about the reporting obligation for CBAM goods that came into effect at that time. To ensure that you, as an importer of CBAM goods, are aware of the reporting obligation, we ask you to enter a fictitious document code when making the customs declaration for these goods. You thereby declare that you are aware of the mandatory reporting requirement for these goods. You do not have to provide a document with the declaration, but you must fill in the document code to make your import declaration. If you do not fill in a fictitious document code, your declaration will not be accepted.

What should you pay attention to when completing your declaration?

  • In your import declaration, enter the following number under documents:
    • 1200
      With this fictitious document code, you indicate that you are aware of the mandatory reporting requirement for the declared CBAM goods.
    • 1300
      With this fictitious document code, you indicate that the CBAM goods you declared are exempt from the mandatory reporting requirement. For example, because the value of the goods is lower than €150.
  • If you do not enter a fictitious document code, the declaration will not be accepted and you will receive an error message. You can then adjust the declaration and submit it again.
  • In the User Tariff (Gebruikerstarief), for all goods covered by the CBAM regulation, we indicate and explain the conditions of the measure of the required document code.

What will change after 1 January 2026?

Importers wishing to import CBAM goods from 1 January 2026 onwards must be approved as CBAM declarants. Apply for the authorisation from the competent authority in the country where you are based. In addition, importers of CBAM goods must purchase CO2 certificates from 1 January 2026 to correct the CO2 emitted in the production of the imported goods. As many CO2 certificates must be handed in annually as CO2 was emitted in the production of the imported CBAM goods. 1 certificate thereby equals the emission of 1 tonne of CO2.

Where can you find more information about CBAM?

The details regarding CBAM are still being developed, especially the rules for the period after the transition period. As soon as more is known, you will read about it on this site.

You can also learn more about CBAM on the website of the European Union.