CBAM is usually told from the exporter’s side — but the party signing the declaration and paying is the EU importer. For importers in the Netherlands and France — two major gateways for Vietnamese goods into the EU — CBAM from 01/01/2026 is an entirely new compliance duty: register, declare, buy certificates, and face penalties for errors.
1. The importer’s duty: the authorised CBAM declarant
Under Regulation (EU) 2023/956, only an authorised CBAM declarant may import CBAM-covered goods (cement, iron and steel, aluminium, fertilisers, electricity, hydrogen). Annual duties: declare import volumes, the embedded emissions of each consignment, and surrender matching CBAM certificates — priced off the EU ETS. Misdeclare or under-surrender: fines and possible loss of status. Dutch and French importers of Vietnamese goods must build internal process from 2026: who collects emissions data from Vietnamese suppliers, who calculates, who files.
2. Data from Viet Nam: the practical bottleneck
Embedded emissions must follow the EU methodology — importers cannot just “estimate” but need producer data from Viet Nam, ideally independently verified. Reality: many Vietnamese exporters lack MRV systems, sending late or non-EU-format data — forcing importers onto default values (higher than reality, costlier) or misdeclaration risk. Fix: write emissions-data duties into purchase contracts — format, deadlines, and sanctions for late delivery; importers proactively coach Vietnamese suppliers on the EU methodology.
3. Certificate-buying strategy and cost management
CBAM certificates must be bought and surrendered yearly — a new cash flow in the import business. Importers need to: forecast CBAM cost per product and supplier for repricing to customers; track EU ETS price moves (CBAM certificates follow); and use the deduction for carbon prices paid in Viet Nam under Article 9 (if Viet Nam adopts carbon tax/ETS in future and the producer paid). For importers, CBAM is not “the exporter’s tax” — it is their own duty and cost.
Conclusion
Dutch and French importers that build a “carbon data pipeline” from Vietnamese suppliers into their filing systems turn CBAM from a compliance risk into a buying advantage.
Frequently Asked Questions
Who may import CBAM-covered goods into the EU?
Only an authorised CBAM declarant under Regulation (EU) 2023/956 may import the six covered groups: cement, iron and steel, aluminium, fertilisers, electricity, hydrogen.
What must importers do each year?
Declare import volumes and per-consignment embedded emissions, and surrender matching CBAM certificates (priced off the EU ETS). Misdeclaration or shortfall draws fines and possible loss of status.
Where do emissions data come from?
From the Vietnamese producer under the EU methodology, ideally independently verified. Build data-supply duties (format, deadlines, late-delivery sanctions) into purchase contracts.
Can carbon prices paid in Viet Nam be deducted?
Yes, under Article 9 of Regulation (EU) 2023/956 — provided it is a mandatory carbon price effectively paid in Viet Nam with proof. Voluntary carbon credits cannot be deducted.
