CBAM Alert: March 31 Deadline Approaching 

The Carbon Border Adjustment Mechanism (CBAM) is playing an increasingly important role in European import regulations. While many companies still see it as a scheme for a limited group of large industrial players. In practice, many more importers are affected than expected. If you import products such as steel, aluminium, cement, fertilizers, electricity or hydrogen. From outside the EU, CBAM may quickly become relevant.

Who does this apply to?

• Companies planning to import more than 50 tons of CBAM goods in 2026 must be registered as a CBAM declarant or appoint an indirect customs representative.
• Companies importing less than 50 tons per year are generally not subject to the obligation (with exceptions for electricity and hydrogen).

At the time of import, customs will check whether the importer or their indirect representative is a registered CBAM declarant. If not, the goods will not be released by customs.

The European Commission has published an amendment to the CBAM regulation that provides temporary relief. Companies that submit a registration application by March 31, 2026, may continue importing CBAM goods while their application is being processed.

Warning: rejection of the application can lead to high fines

This temporary exemption may seem attractive but carries significant risks.

If the Dutch Emissions Authority (NEa) rejects the registration application, a fine for importing without approval is automatically applied. This can amount to:

• 3 to 5 times the standard amount of €100 per CBAM certificate (plus indexation)
• Minimum €100 per certificate, even for minor violations

Although this fine replaces the obligation to submit CBAM declarations and surrender certificates, it can still be financially significant.

What should you do?

• Check whether CBAM applies to your imports.
• Submit a registration application to the NEa by March 31, 2026.
• Ensure the application is complete and accurate to avoid rejection and fines.
• Monitor the status of your application and prepare for future declarations and certificate submissions once your registration is approved.

Need help before March 31?

The CBAM registration process can be complex and incomplete or incorrect applications increase the risk of rejection and fines. We are happy to help you ensure your application is submitted on time and correctly before the March 31, 2026 deadline. Feel free to contact us to discuss risks and the necessary steps.