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Last updated: September 2026
The European sustainability compliance landscape just became more demanding. The Netherlands presented its 2027 Tax Plan, refined the planned levy on fossil-fuel company cars, and expanded an energy-intensive industry subsidy. In parallel, the European Commission released new CBAM guidance documents and updated its packaging FAQ. For US multinationals with EU operations and exporters of carbon-intensive goods, these moves are not routine policy noise — they carry direct compliance and cost implications.
Budget Day in the Netherlands delivered the government’s 2027 Tax Plan to the Lower House. The package includes a range of energy and climate-related tax measures that will affect businesses across the country. KPMG tax professionals have flagged the key changes and their practical impact.
Companies should not treat this as a carbon tax issue only. The plan reinforces a broader trend: climate policy is increasingly embedded in ordinary tax legislation, from energy taxes to vehicle levies. Dutch-based businesses, and their US parent companies, need to model how these measures hit operational costs before the rules take effect.
The Dutch government previously announced a pseudo final levy on fossil-fuel company cars. From 1 January 2027, employers must pay 12% of the list price of fossil-fuel passenger cars made available to employees for private use. Commuting counts as private use. The levy is paid by the employer on top of any benefit-in-kind charge for the employee.
Following stakeholder feedback, several adjustments are now on the table:
There is also a statutory anti-cumulation rule to prevent double taxation where both this levy and the pseudo final levy on excessive severance payments might apply to the same employer and tax base.
For fleet-heavy businesses, the message is clear: accelerate the shift to zero-emission vehicles, but also review transitional relief and exception rules before planning vehicle purchases.
The Netherlands has updated its Indirect Cost Compensation scheme for the EU Emissions Trading System. The program helps energy-intensive companies offset part of the higher electricity costs caused by EU ETS carbon pricing.
The eligible sector list has grown significantly. Producers of fertilisers, ceramic tiles, flat and hollow glass, stone wool, and organic basic chemicals can now apply. Existing coverage for aluminium, iron, paper, hydrogen, and zinc remains in place.
The total budget is €318 million. The application window opened on 3 August 2026 and closes on 30 September 2026. First-time successful applicants are expected to receive subsidies in early 2027.
US-owned companies in the Netherlands should examine whether their Dutch subsidiaries fall within the expanded definitions. This subsidy can meaningfully offset carbon-related electricity costs, so eligibility is worth confirming before the window closes.
Entrepreneurs planning to install charging infrastructure for electric machinery or vehicles on their own or leased premises can still tap into the Private Charging Infrastructure at Businesses Subsidy Scheme, or SPRILA.
The scheme is aimed at businesses investing in private charging points. It remains a practical way to lower the upfront cost of electrifying fleets and materials-handling equipment. Companies with Dutch operations that are expanding electric vehicle use should assess whether SPRILA can support those investments.
The European Commission has released an updated FAQ for Regulation (EU) 2025/40, the new EU framework for packaging and packaging waste. The regulation is designed to help the internal market function smoothly while cutting the environmental and health effects of packaging across its full life cycle.
For US companies selling packaged goods into the EU, the FAQ is a useful starting point for understanding design, labeling, and waste-management obligations. Given the breadth of PPWR, waiting for enforcement signals before acting would be a mistake.
Under the EU’s Carbon Border Adjustment Mechanism, importers must submit annual declarations using either actual verified emissions or default values. If they choose actual emissions, independent verifiers accredited by EU national accreditation bodies must verify the data.
That verification requirement is central to CBAM’s credibility. It is also a compliance step that US exporters sometimes underestimate. Emissions data from non-EU production sites now has to meet EU verification standards, and that requires robust documentation and internal controls.
The European Commission has published a series of guidance documents for the CBAM definitive period. Four general guides cover core concepts, and six sector-specific guides go deeper into production realities.
Any company involved in producing or importing CBAM goods should review the relevant sector guide. The Commission’s materials also highlight the importance of using actual values for 2026 imports, putting strong monitoring processes in place, and understanding how embedded emissions calculations changed after the transitional period.
For organizations working in the defence or dual-use space, KPMG’s latest Global Credits, Grants and Incentives newsletter maps funding sources across Poland, Germany, Spain, Portugal, the United States, and Canada. It is a practical introduction for companies looking to support R&D, industrial investments, and the scaling of innovative technologies.
Sustainability-related tax and legal work now spans carbon, packaging, energy, reporting, and more. KPMG’s specialists help companies navigate ESG requirements, manage risks, and identify value-creation opportunities across their operations.
There is a natural temptation to treat EU CBAM and Dutch tax changes as “European issues.” For US exporters of cement, iron and steel, aluminium, fertilisers, hydrogen, or electricity, that would be a costly misread. CBAM applies to goods imported into the EU, regardless of where the production facility sits. That means US plants can become subject to EU data reporting and verification requirements.
The new Commission guidance is useful, but it also signals that the definitive period has arrived. Importers need to decide between default values and actual verified emissions. Default values are simpler, but they can be more expensive. Actual emissions require credible measurement, monitoring, and an accredited verifier.
The practical move for US exporters is to run a gap assessment now: map each affected product, identify the emissions data available at the plant, review the sector guidance, and estimate the cost difference between default values and verified actuals. For US-owned companies with Dutch sites, add the 2027 Tax Plan, the company car levy, and the expanded IKC ETS scheme to the list.
None of these measures should be read in isolation. Carbon costs are spreading across tax, subsidy, and border rules at the same time. Businesses that connect the dots early will be in a stronger position to manage compliance and protect competitiveness.
