16/09/25
In the area of climate, energy, and mobility, the 2026 Tax Plan package includes a number of important measures. Although there is a lack of clear focus in these measures, maintaining a level playing field for Dutch companies and preventing an unnecessary increase in burden appears to be a key objective. In this article, you can read about the most important changes, with an emphasis on the national CO₂ levy. In addition, you will find an overview of other relevant measures for businesses. Besides being important for the energy-intensive industries, the changes also affect, among others, the logistics sector and companies active in the circular economy. Due to the interplay between national and European regulations, it is important to follow these developments closely and to prepare proactively for both the fiscal and operational consequences.
The impact of the measures in the 2026 Tax Plan package for the waste sector may be found in a separate Tax News article 'Verhoging CO₂-heffing voor afvalverbrandingsinstallaties' (only in Dutch).
Via the national CO₂ levy, the Netherlands has an additional levy on top of the EU ETS, the so-called 'nationale kop'. Due to the uneven playing field that this creates and the accompanying risk of production being relocated abroad, there is a lot of discussion about the national CO₂ levy. Despite a motion by the House of Representatives to completely abolish the national CO₂ levy for industry as soon as possible, it has now been decided to only adjust the rate of the CO₂ levy.
For industry, reducing the CO₂ levy rate from 87.90 euros in 2025 to 78.67 euros per tonne of CO₂ from 2026 to 2030 means lower to no costs and more clarity in the short term. On the one hand, because this rate is expected to remain below the EU ETS price from 2027 and the levy will therefore effectively not be due from 2027. On the other hand, because the expansion of dispensation rights is intended to ensure that companies that are in line with the European ETS sustainability objectives are effectively fully exempt from the CO₂ levy from 2026.
There is no question of a (complete) withdrawal of the CO₂ levy (for the time being), because the CO₂ levy was part of a package of measures to claim funds from the European covid recovery fund. An adjustment of the rate per ton of CO₂ of more than 5 percent compared to the promised 82.80 euros per ton of CO₂ in 2026 would lead to a discount on the (to be received) funds. Therefore, the maximum 5 percent deviation has been used, leading to the aforementioned rate of 78.67 per tonne of CO₂ from 2026.
The national CO₂ levy is expected to be slightly above the EU ETS price in 2026. Taxpayers covered by the EU ETS only pay the CO₂ levy insofar as the rate exceeds the EU ETS price and the number of dispensation rights. In 2026, taxpayers would therefore still pay a national CO₂ levy based on the expected EU ETS price. Although the EU ETS price depends on many factors, the new CO₂ levy rate from 2027 onwards is expected to be below the EU ETS price level, or the emissions should be covered by dispensation rights with parties that are in line with the EU ETS. This should lead to the levy being effectively suspended for (the vast majority of) industry from 2027 to 2030. This will allow companies to invest more in sustainability and innovation until at least 2030, without being confronted with an additional national burden on top of EU ETS price.
For 2030 and beyond, this leaves companies in uncertainty. The government has previously announced that it will develop a technical variant for the CO₂ levy after 2030, in which the rate can rise to 216 euros per tonne for non-exempt emissions after 2035. At the same time, the government is open to alternatives that guarantee the necessary reduction and contribute to achieving the climate goals for 2050. In the coming years, it will have to become clear whether the national tax will be definitively abolished, replaced by other instruments, or return in a modified form. We will follow developments closely and for the time being, investment plans will have to take this uncertainty into account.
The fact that the Netherlands is out of step within Europe regarding this measure is also demonstrated by the ‘2025 playing field test' by PwC/Strategy& (in Dutch only). Companies are limited by limited availability of capacity on the electricity grid, H₂ and CO₂ transport and storage infrastructure, and nitrogen issues which limit permits granted. As a result, there is only a small scope for action, which leads to a (disproportionate) distortion of the playing field. As such, more clarity about the national CO₂ levy after 2030 would be highly desirable.
For waste incineration plants (AVIs), on the other hand, the CO₂ tax will increase. In addition, as a technical measure, the exempted emissions for waste incineration plants will be adjusted. Until 2030, the levy target will remain the same as the baseline path, namely 0.6 megaton of (fossil) CO₂ emissions in 2030. After 2030, exempted emissions will fall in equal steps to zero in 2033. As a third measure, trade in dispensation rights between waste incineration plants and other industrial plants is excluded. This prevents waste incineration plants from being able to buy dispensation rights from other industrial installations, which would put pressure on the intended incentive for emission reduction and the intended budgetary return. After all, the rate for waste incineration plants is higher, and is not (yet) corrected for the ETS price. Yet, from 2028 onwards, AVIs could be included in the EU ETS. The European Commission shall report on its feasibility assessment by 31 July 2026 at the latest.
In this context, the question is whether this increase will have the desired effect and actually improve the business case for CO₂ capture and storage (CCS), among other things. The playing field test (in Dutch only) that PwC/Strategy& carried out (in September 2025) for the Dutch Association of Waste Companies makes some critical comments on this. For more information and background, also see our Tax News article 'Verhoging CO₂-heffing voor afvalverbrandingsinstallaties' (only in Dutch).
From 2026, the European Carbon Border Adjustment Mechanism (CBAM) will effectively come into force. The obligation to purchase CBAM certificates for the import of goods such as cement, steel, aluminium, fertilisers, electricity and hydrogen will be phased in until 2034. This mechanism ensures that imported goods from countries with less stringent climate rules are taxed with a CO₂ price, so that the playing field between European and foreign producers becomes more level. For more background, see also CBAM explained.
It was recently proposed to limit the scope of the CBAM to imports of at least 50 tonnes net mass for cumulative imports of CBAM products (on average, around 80 tonnes of CO₂ equivalent per importer). As a result, it is expected that 90 percent of importers who are currently subject to CBAM obligations will fall outside the scope. See also the impact of the omnibus proposal on taxation for more information.
The administrative obligations for CBAM already apply. For companies that import CBAM products, this means that for imports from 2026 onwards they will actually have to pay for CBAM certificates (no later than 30 September 2027). To operationalise this, the Environmental management act (‘Wet milieubeheer’) includes various purely implementation-oriented measures as part of the 2026 Tax Plan package.
In addition to the changes to the CO₂ levy and the waiver of the plastic levy, the 2026 Tax Plan package contains a series of other measures that are relevant for businesses:
Partner, Energy transition and sustainable energy, PwC Netherlands
Tel: +31 (0)65 160 08 61
Juliette Marsé
Director (Tax) - Energy, Utilities & Resources, PwC Netherlands
Tel: +31 (0)63 419 61 08
Mohammed Azouagh
Senior Manager - Tax, Sustainability and Incentives, PwC Netherlands
Tel: +31 (0)62 380 36 54