Dubrink is a CBAM compliance platform with published importer pricing from €1,990 per year (as of July 2026) and free "Connect" tiers on both the importer side and the supplier side, a two-sided pricing design that is unusual in the CBAM software category. EU importers handling between the 50-tonne de minimis threshold and 15,000 tonnes of CBAM goods per year, and non-EU suppliers that must deliver embedded emissions data to EU customers, are the two buyer groups that should shortlist Dubrink. Three buyer profiles should look elsewhere: import groups with multiple legal entities (every paid tier covers exactly 1 entity), importers above 15,000 tonnes per year or 50 suppliers (both trigger custom enterprise pricing), and buyers who require a documented direct submission channel to the CBAM Registry, because Dubrink's site describes XML file generation for declarations rather than a registry integration.
This review covers what Dubrink does against each definitive-phase obligation, its full published price list, how it compares with Coolset, CBAMboo, and Kolum, and where its limits sit. All vendor facts were verified against Dubrink's public pricing and product pages on July 10, 2026. cbamguide.com has no commercial relationship with Dubrink, and the position of this review in our best CBAM software roundup is editorial only.
What Dubrink Does for CBAM Compliance
Dubrink covers four of the five operational workstreams the CBAM definitive phase imposes on an authorized declarant: supplier data collection, embedded emissions calculation, declaration file preparation, and certificate cost forecasting. The fifth workstream, verification of embedded emissions by an accredited verifier, remains an external service under every software platform, although Dubrink provides audit and verification access so a verifier can review the underlying data. The table below maps each obligation under Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083, to the corresponding platform feature.
| Definitive-phase obligation | Rule or deadline | Dubrink feature |
|---|---|---|
| Collect actual emissions data from suppliers | Actual data avoids the marked-up defaults of IR 2025/2621 | Real-time supplier data exchange, free supplier Connect tier, communication templates |
| Calculate embedded emissions | Methodology under Regulation (EU) 2023/956 | In-platform CBAM calculation |
| File the annual CBAM declaration | First deadline September 30, 2027, covering 2026 imports | PDF and XML report generation |
| Manage certificate purchases and cost | Sales open February 1, 2027; Q2 2026 price €75.28/tCO₂e | Emissions and cost forecasting ("emission budgeting"), analytics |
| Support verification and audits | Accredited verifier required for declared emissions data | Audit trails, verification access, alerts, cloud storage |
Supplier Data Collection Through the Two-Sided Network
Dubrink's core differentiator is that suppliers are first-class users, not just email recipients of data request templates. A non-EU supplier can hold a free Connect license (1 entity, CBAM calculation, data exchange, communication templates) or a paid Premium license at €1,990 per year (as of July 2026) covering multiple entities, sub-supplier connections, and data export. Supplier participation matters financially because importers who rely on default values instead of actual supplier data pay the marked-up figures set in Implementing Regulation (EU) 2025/2621, and the CBAM default values are calibrated to be more expensive than verified actual emissions in most cases. A platform that lowers the supplier's cost of participation to zero addresses the single most common data bottleneck in the importer workflow.
The reciprocity works in both directions. An importer whose suppliers hold paid licenses gets the free importer Connect tier, and a paying supplier grants its importers free access to its data. Dubrink positions the platform for the whole chain: importers, suppliers, distributors, customs representatives, consultants, and verifiers.
Declaration Preparation: XML Output, Not Registry Submission
Dubrink generates the annual declaration as PDF and XML files on the Starter tier and above. The first CBAM declaration is due September 30, 2027, covering calendar-year 2026 imports, and is filed through the CBAM Registry by the authorized declarant. Dubrink's site does not claim a direct API connection to the CBAM Registry: the documented mechanism is file generation, which means the declarant handles the submission step. Buyers who expect end-to-end filing should confirm the submission workflow with the vendor before contracting.
Certificate Cost Forecasting
Dubrink's "emission budgeting" feature forecasts emissions and certificate costs, which maps to two financial obligations that begin in 2027. Certificate sales open February 1, 2027, and from that point authorized declarants must hold certificates covering at least 50% of cumulative embedded emissions at each quarter end, as explained in our guide to CBAM certificates. The cost side stays modest in the first year: at the official Q2 2026 certificate price of €75.28/tCO₂e (published July 6, 2026) and the 2026 CBAM factor of 2.5%, an importer of 1,000 tonnes of blast-furnace steel (roughly 2,000 tCO₂e embedded) faces a net certificate cost near €3,764 for the year. The CBAM price tracker publishes each quarterly official price as the European Commission releases it. Forecasting tools earn their keep from 2027 onward, when the quarterly holding requirement starts and the CBAM factor begins its climb toward 100% by 2034.
Dubrink Pricing (as of July 2026)
Dubrink publishes its full price list in EUR with annual billing, verified on July 10, 2026 at dubrink.com/cbam-software-pricing. The 6 published tiers across both license types are listed below.
| License side | Tier | Annual price (as of July 2026) | Scope |
|---|---|---|---|
| Importer | Connect | Free (requires paying suppliers) | 1 entity, unlimited tonnes/year, analytics, forecasting; published feature list shows PDF reports, with XML listed from Starter upward |
| Importer | Starter | €1,990 | 1 entity, up to 1,000 t/yr, up to 10 suppliers, PDF and XML reports |
| Importer | Premium | €2,990 | 1 entity, up to 15,000 t/yr, up to 50 suppliers |
| Importer | Enterprise | Custom | Multiple entities, unlimited tonnes and suppliers |
| Supplier | Connect | Free | 1 entity, CBAM calculation, data exchange, communication templates |
| Supplier | Premium | €1,990 | Multiple entities, sub-supplier connections, export |
Three pricing details deserve attention before budgeting:
- The free importer tier is conditional. Connect is available when your suppliers hold paid licenses ("Paying Suppliers Only"). Its published feature list includes PDF reports, while XML file output is listed from the Starter tier upward, so an importer that needs documented XML output for its own filing should budget from €1,990 per year or confirm Connect's export scope with the vendor.
- The tonnage bands are wide at the bottom and hard-capped at the top. Starter's 1,000 t/yr ceiling comfortably covers importers just above the 50-tonne de minimis exemption, which already removes roughly 90% of importers from CBAM obligations entirely. Premium's 15,000 t/yr and 50-supplier caps mark the boundary where custom enterprise pricing begins.
- Billing is annual only. No monthly option is published, and CBAM Academy training (three programs: CBAM Fundamentals, Supplier Onboarding, Consultant Certification) is priced on request.
For context, a Starter license at €1,990 per year costs less than the net 2026 certificate obligation on about 530 tonnes of blast-furnace steel at current prices. From 2027, when the CBAM factor doubles to 5% and certificate purchases begin, software cost becomes a small line item next to certificate spend for most importers above 1,000 tonnes per year.
Dubrink vs Coolset, CBAMboo, and Kolum
Dubrink's published entry price and its free supplier tier are its clearest points of difference inside our software cluster. The table below positions Dubrink against three alternatives we review separately; each linked review contains that vendor's verified pricing and feature detail.
| Criterion | Dubrink | Alternatives |
|---|---|---|
| Published pricing | Yes, full price list public (€1,990 to €2,990/yr importer tiers, as of July 2026) | Varies by vendor; see each review |
| Free tier | Yes, on both importer and supplier side (conditions apply) | See Coolset review, CBAMboo review, Kolum review |
| Supplier-side licenses | Yes, free Connect and €1,990/yr Premium (as of July 2026) | See individual reviews |
| Declaration output | PDF and XML file generation | See individual reviews |
| Documented sweet spot | Single-entity importers up to 15,000 t/yr and 50 suppliers | See individual reviews |
Two shortlisting heuristics follow from this positioning. Importers whose main blocker is supplier participation gain the most from Dubrink's free supplier tier, because the zero-cost entry point removes the standard supplier objection to yet another portal. Importers who need multi-entity coverage, higher volumes, or a broader carbon accounting scope beyond CBAM should compare the alternatives in our best CBAM software roundup, where we rank each platform by buyer profile rather than by a single score.
Company Background
Dubrink s.r.o. is a Czech limited liability company founded in July 2024, with its registered office at Kaprova 42/14, Prague 1, and a listed office in Rotterdam, Netherlands. Describing Dubrink as a Dutch or Rotterdam-headquartered company is legally inaccurate: the legal seat is Prague (Municipal Court in Prague, file C 406499), although both managing directors are Dutch. Leadership consists of Marcel Duits, Chief CBAM Officer, formerly of Unilever and Erasmus University Rotterdam, and Jan-Joost den Brinker, CTO. No funding rounds or investors could be verified, so the company should be treated as bootstrapped or undisclosed on financing.
The company is active as a publisher. Its Updates section carries a recurring "Dubrink Weekly" regulatory analysis, practical guides such as an April 2026 walkthrough on becoming a CBAM authorized declarant, UK CBAM draft legislation coverage, and demo videos, alongside the CBAM Academy training programs. Dubrink's homepage states figures of 1.4K+ connected companies and 900K+ processed import lines; these are vendor-reported marketing numbers that we could not independently verify, and no third-party review data was accessible during our research.
Limitations of Dubrink
Six limitations stand out for buyers evaluating Dubrink in 2026:
- Single-entity paid tiers. Every published importer tier covers 1 legal entity. Import groups with 2 or more declarant entities move straight to custom enterprise pricing.
- Hard ceilings at 15,000 t/yr and 50 suppliers. Mid-market importers near either cap should price the enterprise tier before committing, since no published rate exists above Premium.
- No documented registry submission channel. The platform generates XML declaration files; the site does not claim direct API integration with the CBAM Registry, so the filing step stays manual.
- Conditional free importer tier. Connect requires paying suppliers, and its published feature list shows PDF reports while XML output is listed from Starter upward, which limits its documented usefulness for a declarant's own filing obligations.
- Short operating history. The company was founded in July 2024, giving it under 2 years of track record at the time of this review, and its traction figures are self-reported.
- Untested integration and language claims. Compatibility with ERPs, customs systems, and production software, onboarding "in days, not months", and availability in English plus 12 European languages are vendor claims we did not independently test.
None of these limitations affects the underlying compliance logic, which follows the standard CBAM calculation methodology, but each one shapes which buyer the platform fits. Data quality obligations also remain with the declarant regardless of tooling: emissions figures declared in September 2027 must pass accredited CBAM verification, and software output is only as reliable as the supplier data entered into it.
How We Evaluate CBAM Software
cbamguide.com is an independent editorial site with no affiliate relationships, referral fees, or paid placements from any vendor covered in the CBAM software cluster. Our method for this review followed 4 steps: we verified every price and feature claim against Dubrink's public pricing and product pages on July 10, 2026, cross-checked the corporate facts against Czech commercial register records, excluded claims we could not verify or marked them as vendor-reported, and mapped the verified feature set against the actual obligations that EU importers face under the definitive phase. We do not publish invented review scores, star ratings, or user quotes. Where a fact rests solely on the vendor's own statements, this review says so.
Frequently Asked Questions About Dubrink
How Much Does Dubrink Cost?
Dubrink's paid importer licenses cost €1,990 per year (Starter: 1 entity, up to 1,000 t/yr, 10 suppliers) or €2,990 per year (Premium: 1 entity, up to 15,000 t/yr, 50 suppliers), as of July 2026. Supplier licenses cost €0 (Connect) or €1,990 per year (Premium). Enterprise pricing for multi-entity importers is custom. Billing is annual and in EUR.
Is There a Free Version of Dubrink?
Yes, on both sides of the supply chain, with conditions. Suppliers get a free Connect license covering 1 entity with CBAM calculation, data exchange, and communication templates. Importers get a free Connect license only when their suppliers hold paid licenses; the published Connect feature list includes PDF reports, while XML file output is listed from the Starter tier upward, so importers who need XML should confirm the export scope with the vendor.
Does Dubrink Submit Declarations Directly to the CBAM Registry?
No such capability is documented on Dubrink's site as of July 2026. The platform generates the declaration as PDF and XML files, and the authorized declarant files through the CBAM Registry itself. Buyers who need a confirmed submission workflow should raise this directly with the vendor during a demo.
Who Is Behind Dubrink and Where Is It Based?
Dubrink s.r.o. is a Czech limited liability company founded in July 2024, with its registered office in Prague and a listed office in Rotterdam. The managing directors are Marcel Duits (Chief CBAM Officer) and Jan-Joost den Brinker (CTO). Funding details are undisclosed.
Does Dubrink Suit Non-EU Suppliers and Exporters?
Yes, supplier-side use is central to the product design. Non-EU suppliers can calculate embedded emissions and exchange data with EU customers on the free Connect tier, or upgrade to the €1,990 per year Premium supplier license (as of July 2026) for multiple entities and sub-supplier connections. Our guide for exporters explains what data EU importers will request and why supplying actual figures beats leaving customers on default values.