The Royal Dutch Steel Federation has stated that the introduction of the EU’s Carbon Border Adjustment Mechanism (CBAM) is expected to place significant short-term pressure on the Dutch manufacturing industry, particularly in the steel sector.
While CBAM aims to prevent carbon leakage by aligning import carbon costs with those faced by EU producers, Dutch steel importers warn that the current implementation framework is generating substantial uncertainty and cost risks.
Imports made in 2026 will only be financially settled in 2027. However, the absence of a clear and operational verification procedure leaves importers uncertain about the actual carbon costs they will ultimately face. As a result, pricing decisions become more complex and higher costs are likely to be passed on to customers in the Dutch manufacturing sector. The situation is further complicated by the fact that no comparable carbon levy has yet been introduced for many downstream products, raising concerns about potential distortions in competition.
Operational and administrative challenges
Companies report multiple operational difficulties linked to CBAM compliance. The system is described as complex, and existing calculation tools and standard emission values are viewed as insufficiently aligned with real production data.
In several cases, long-term contracts have become economically unviable due to sharply increased carbon cost assumptions. Importers bringing in more than 50 mt of steel or aluminum must register in the CBAM registry and obtain approval from the Dutch Emissions Authority (NEA), adding further administrative obligations.
Concerns over mandatory default values
A key concern is the mandatory use of “default values” for embedded carbon emissions. These standard values, set by the European Commission, can be significantly higher than companies’ actual emissions, which are often already documented under frameworks such as CSRD reporting.
Because a formal verification mechanism for real emissions data is not yet operational, companies are required to apply these elevated default values. According to the Federation, this inflates steel prices artificially without reflecting the true carbon footprint of the products concerned.
The association warned that such distortions could shift demand toward downstream goods imported from outside the EU that are not covered by CBAM, potentially undermining the level playing field and disadvantaging both the steel supply chain and Dutch industrial users.
Call for simplification and faster verification
The Royal Dutch Steel Federation has called for simplification of the CBAM system and the accelerated introduction of a practical verification mechanism by July 1, 2026, at the latest. Enabling the use of verified actual emissions data, the group argues, would reduce artificial cost inflation and provide greater price certainty for businesses.
In parallel, the Federation is conducting impact assessments based on case studies and member data to identify the most affected product categories, particularly those facing high default values and limited European supply. Based on these findings, it plans to submit policy recommendations at both national and EU levels to ensure that CBAM achieves its environmental objectives without undermining industrial competitiveness.
While supporting CBAM’s overarching goal of preventing carbon leakage and promoting fair competition, the Federation stressed that the current implementation framework poses significant risks for the competitiveness of Dutch industrial users of steel and metal products.
