Climate and energy measures

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).

What does the adjustment of the CO₂ tax mean for your company?

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.

Effect as of 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.

Level playing field

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.

Waste processing plants: increase in CO₂ levy

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).

The EU CO₂ border levy: the Carbon border adjustment mechanism (CBAM)

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.

Overview of other measures on environment, energy and mobility

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:

  • No reintroduction of red diesel: the previously intended introduction of red diesel has been scrapped. The budgetary proceeds of this measure will be used to extend the discount on fuel excise duty by one year, see below.
  • Lorry charge: from mid-2026, a lorry charge of an average of 0.186 euros per kilometre driven will be introduced for all lorries from 3,500 kilos. This charge applies to motorways and several national roads (‘N-wegen’) and municipal roads. At the same time, the motor vehicle tax for lorries will be reduced and the Eurovignette will be abolished.
  • Fuel excise duty reduction: the reduction in excise duty on petrol, diesel and LPG will be extended by one year and will not be indexed until the end of 2026, in order to cushion price increases for businesses and consumers.
  • Excise duty refund for RFNOs: The excise duty refund scheme for motor fuel containing or consisting of renewable fuel will be adjusted by stipulating that it is renewable fuel of non-biological origin (RFNBO). This adjustment follows from the implementation of the articles of the EU Renewable Energy Amendment Directive (RED III) that relate to the transport sector.
  • MRB and addition to taxable income for electric cars: for emission-free cars, the rate discount for motor vehicle tax (MRB) will be increased to 30 percent in the period 2026-2028, making the tax burden of heavy electric and fossil cars almost the same. For smaller and medium-sized vehicles, the differences are narrowing. From 2026, the same addition (22 percent) will apply to new electric cars as to non-electric cars.
  • Tax on tap water: the definition of tap water will be broadened to "water of drinking quality", the levy ceiling will be extended from 300 cubic metres to 50,000 cubic metres in 2026 and small water suppliers (fewer than 1,000 connections) will also become subject to tax.
  • Waste tax: for the time being, tax rates for landfill, incineration and shipment of waste will increase from 2028, to cover the annual budgetary gap of 567 million euros due to the non-introduction of the polymer levy. The exemption for the incineration of sewage sludge will expire in 2027.
  • Energy tax: the energy tax will be reduced via the generic tax reduction, which has been set at 519.80 euros (ex VAT) for 2026 per self-employed connection for a residential function.
  • Differentiation of flight tax: as of 2027, the flight tax will be adjusted by introducing different rates depending on the distance and environmental impact of the flight. The tax is 29.40 euros (final destination 0-2,000 km), 47.24 euros (2,000-5,500 km) or 70.86 euros (above 5,500 km or at undeterminable final destination).
  • Hydrogen: a reduced energy tax rate will be introduced for the energy use of pure hydrogen, equal to the electricity rate in the fifth bracket. ‘Grey’, ‘blue’ and ‘green’ hydrogen are taxed equally. In addition, the exemption from energy tax for electricity used in electrolytic processes will be extended, including for the production, purification and compression of hydrogen.
  • Other incentives and subsidies: there are various subsidies and tax schemes available for sustainability investments, such as the Stimulation Sustainable Energy Production and Climate Transition (SDE++), the Energy Investment Allowance (EIA), and the Environmental investment rebate (MIA). In 2026, the government will make 150 million euros available for the extension of the ETS Indirect Cost Compensation Subsidy Scheme until 2028. The government is also investing 230 million euros in the upcoming IPCEI schemes, aimed at the semiconductor sector. The SDE scheme, on the other hand, will be cut to 8 billion euros next year, partly due to lack of use. For the circular plastics sector, a linked CAPEX-OPEX subsidy scheme is being worked on and a plea is being made for a reduction in energy tax, following the German example.

Contact us

Niels Muller

Niels Muller

Partner, Energy transition and sustainable energy, PwC Netherlands

Tel: +31 (0)65 160 08 61

Juliette Marsé

Juliette Marsé

Director (Tax) - Energy, Utilities & Resources, PwC Netherlands

Tel: +31 (0)63 419 61 08

Sander Borremans

Sander Borremans

Senior Manager Indirect Taxes, PwC Netherlands

Tel: +31 (0)61 029 42 75

Claudia Buysing Damsté

Claudia Buysing Damsté

Partner, PwC Netherlands

Tel: +31 (0)65 103 04 63

Mohammed Azouagh

Mohammed Azouagh

Senior Manager - Tax, Sustainability and Incentives, PwC Netherlands

Tel: +31 (0)62 380 36 54

Marc Hogenhuis

Marc Hogenhuis

Manager Sustainability, PwC Netherlands

Tel: +31 (0)68 136 28 48

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