CBAM, the EU Carbon Border Adjustment Mechanism, puts a carbon price on imported goods so that products made outside the EU carry the same CO₂ cost as goods made under the EU Emissions Trading System. Since 1 January 2026 CBAM is in its definitive phase: it's no longer just reporting, there are real financial obligations. If you import the covered goods, this affects you. Nexport Logistics can file your CBAM declaration as your indirect customs representative, handled alongside your Customs clearance in the Nexportal platform.
Which goods fall under CBAM
CBAM covers six sectors (Annex I of the EU Regulation):
- Iron and steel (broadly CN chapters 72 and many 73 articles)
- Aluminium (CN chapter 76)
- Cement (mainly CN 2523)
- Fertilisers (parts of chapters 28/31, e.g. ammonia, nitric acid, nitrates)
- Hydrogen (CN 2804 10)
- Electricity (CN 2716)
The exact, binding list of CN/HS codes is published by the Dutch Emissions Authority (NEa). Always confirm your product against the official list of CBAM goods and the EU Regulation Annex I.
The 50-tonne threshold
A de minimis threshold of 50 tonnes of CBAM goods per importer per year is decisive. Import less than 50 tonnes and you are exempt from the financial obligations (exception: no threshold applies to hydrogen and electricity), but you still note this in the customs declaration with code Y137. Import more, and the full obligations apply. Note: the threshold is per importer, not per customs representative.
What an importer must do (since 2026)
- Become an authorised CBAM declarant. Apply at the NEa before importing more than 50 tonnes per year; the NEa has up to 120 days to decide. Transitional rule: whoever filed the application by 31 March 2026 may keep importing CBAM goods while awaiting the decision.
- File the annual CBAM declaration in the CBAM registry, reporting the embedded CO₂ emissions of the goods.
- Surrender CBAM certificates. Buy and hand in as many certificates as the reported emissions (1 certificate = 1 tonne CO₂). Certificate sales start in 2027; the first declaration, covering 2026 imports, is filed in 2027.
CBAM applies when goods enter free circulation (or inward processing). Your CBAM account number goes into the customs declaration.
Indirect customs representation: the practical route
Most of the hassle lives in this part:
- If you, the importer, are not established in the EU, you cannot be the CBAM declarant yourself. An indirect customs representative must be admitted as the authorised CBAM declarant and takes on the obligations.
- If you are EU-established, an indirect customs representative can agree to act as your CBAM declarant and assume the obligations, by clear agreement between the parties.
When the representative takes on the CBAM duties, the NEa holds them accountable for compliance. So it has to be done right.
How Nexport Logistics handles CBAM
We act as your indirect customs representative, admitted as the authorised CBAM declarant, and file the CBAM declaration for you. We handle the NEa authorisation, the emissions reporting in the CBAM registry and the certificates. And because it sits in the same house as your Customs declaration and your sea or air shipment, the CBAM account number and the customs entry line up automatically.
Nexport Logistics is a freight forwarder under the FENEX conditions, with its own customs declarants, and you follow everything in the Nexportal portal. Importing CBAM goods? Email info@nexportlogistics.nl and we'll set up the representation.
Official sources: Douane — CBAM · NEa — indirect customs representatives. Related: Customs · Sea Freight · Air Freight