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% of that value and Belgium for 6.9%.
The countries’ combined share makes Rotterdam and Antwerp important physical gateways for goods classified under current CBAM codes entering European industry. But a port does not determine the final industrial market for imported products, which may be consumed in a different country from where they enter the EU.
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. Other customs procedures can lead to different import consequences and require case-by-case treatment.
A Dutch importer supplying 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. The CBAM authorisation authority 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 enough to identify the authorised CBAM declarant. Importers need records of product classification, origin, quantities, supplier installations and relevant embedded emissions.
Traders 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 focused on Rotterdam and Antwerp should prioritise import terminals, metal trading houses and distributors, then map their documented inland customer relationships. Strong research can follow one product and one supply corridor from the exporting installation to the EU industrial buyer. Ranking ports by value is useful, but identifying who takes title, who declares and who pays helps establish how CBAM affects European manufacturing.