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Carbon adjustment at the border on EU imports (CBAM)

Published by:
Netherlands Enterprise Agency, RVO
2 min read

Do you import goods from outside the EU? Your import may be covered by the rules set in the Carbon Border Adjustment Mechanism (CBAM) Regulation. If this is the case, you must have an authorisation to import these goods. You must also submit a CBAM declaration and pay for the CO2 emitted during the production of these goods.

To whom does the CBAM apply?

The CBAM rules apply to importers of CBAM goods. Whether your goods are covered by CBAM depends on the type of goods, the country where they were produced, and how much of these goods you import.

Which goods are covered by CBAM?

CBAM applies to imports of goods in the following categories:

  • iron and steel
  • cement
  • fertilisers
  • aluminium
  • electricity
  • hydrogen

You can tell whether a product is covered by CBAM by its CN code. Check the full list of CBAM goods and CN codes in Annex I of the CBAM regulation.

If the CBAM goods were produced outside the European Economic Area (EEA) or Switzerland, and you import more than 50 tonnes CBAM goods per year into the EU, you must comply with the CBAM regulation. Do you import hydrogen or electricity? Then the CBAM always applies to you, even if you import less than 50 tonnes per year.

Who is the CBAM declarant?

In many cases, the importer is the CBAM declarant. Are you using indirect customs representation? Then either the indirect customs representative, or the importer may file the CBAM report. If you are established outside the EU, the indirect representative is always the CBAM declarant.

The CBAM declarant applies for authorisation, submits the CBAM declaration, and purchases CBAM certificates.

Applying for authorisation before importing goods

If you want to import more than 50 tonnes CBAM goods per year, or hydrogen or electricity, you must apply for prior authorisation. Without prior authorisation, you cannot import the goods.

Are you using indirect customs representation? Indirect customs representatives responsible for the CBAM declaration must always apply for the status of CBAM declarant, even if they import less than 50 tonnes of CBAM goods per year.

You can apply for admission as a CBAM declarant via the Authorisation Management Module (AMM). To do so for the Netherlands, you will need eHerkenning level 3.

Submitting CBAM declaration and handing in certificates

As a CBAM declarant you must submit a CBAM declaration each year before 1 October for the goods you imported in the previous calendar year. This declaration is mandatory if you imported more than 50 tonnes of CBAM goods in the previous year. In the CBAM declaration, you must state, among other things, how many CBAM goods you have imported and how much CO2 was emitted during their production, the so-called embedded emissions. Check the requirements for your sector.

You must pay for the imported embedded emissions with CBAM certificates. In the CBAM declaration, you state how many certificates you must hand in. You have to hand in that number of certificates annually before 1 October. You must ensure that you have purchased sufficient certificates in advance.

You submit your CBAM declaration and the CBAM certificates via the European Commission's CBAM register. You need eHerkenning level 3 to log in.

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