The Netherlands and Belgium together represented 19.6% of the EU’s 2025 extra-EU import value for products classified under current Carbon Border Adjustment Mechanism (CBAM) codes, according to rounded reporting-member-state shares derived from Eurostat Comext. The Netherlands accounted for 12.7% and Belgium for 6.9%; the figures describe reported import value, not the amount of goods physically handled at their ports.
The countries’ position makes Rotterdam and Antwerp important physical gateways for these products entering European industry. But a port does not establish where goods are ultimately consumed. Steel, aluminium, fertilisers and other materials may be cleared for free circulation, moved into storage, processed by specialised firms or transported to manufacturers elsewhere in Europe.
A Dutch importer selling material to a German or French plant may carry the reporting obligation, even when the material’s embedded emissions and carbon costs matter most to a buyer hundreds of kilometres away. Other customs procedures can lead to different import consequences and require case-by-case treatment.
The authority responsible for CBAM authorisation is determined principally by where the authorised declarant is established, not automatically by the port where a ship discharges. Companies should map customs representatives, importers, consignees, warehousing businesses and industrial purchasers as separate entities. A general shipping database showing a port arrival is not sufficient to identify the authorised CBAM declarant.
Importers need records of product classification, origin, quantities, supplier installations and relevant embedded emissions. Traders working with multiple suppliers and downstream customers need to allocate consignments consistently, retain audit trails and respond to verification requests. Digital integration between customs systems, enterprise procurement and supplier carbon records can reduce administrative errors and improve contracting.
Research centred on Rotterdam and Antwerp should prioritise import terminals, metal trading houses and distributors, then map their documented inland customer relationships. The strongest research stories will follow one product and one supply corridor from the exporting installation to the EU industrial buyer.
Ranking ports by value helps identify important entry points, but tracing who takes title, who declares and who pays shows how CBAM affects European manufacturing. The authorised declarant’s establishment and the consignment’s onward route are therefore central to understanding where reporting responsibilities sit.
