About
The 'Fit for 55 Package' contains regulations adopted in order to cut net greenhouse gas emissions by at least 55% by 2030, compared to 1990 levels. CBAM is a part of this package and will, in the European Commission's view, serve as an essential element of the EU toolbox to meet the objective of a climate-neutral EU by 2050 in line with the Paris Agreement by addressing risks of carbon leakage. The 'carbon charge' is an example of the EU controlling unwanted and climate-hostile business, importation and production, and is part of the EU playing a lead role in global climate action. In general, imposing such charges on unwanted business is proven effective, and we expect more of such duties to be introduced in the future in order to reach the global climate goals.
CBAM applies to certain goods originating in third countries that are considered major contributors to carbon footprints when imported to the EU, ensuring equivalent carbon pricing for imports and domestic products. The goods currently covered by CBAM are cement, electricity, fertilisers, iron and steel, aluminium, and hydrogen, as well as indirect emissions.
Products produced in Norway and imported to the EU from Norway will not be covered by CBAM, and thus CBAM should not have an impact on the pricing of products produced in Norway. However, CBAM will apply to Norwegian businesses importing goods produced in third countries to the EU or Norway, implying that Norwegian importers must have authorisation to import CBAM goods.
One objective of CBAM is to prevent carbon leakage by targeting production in third countries that are less ambitious in their climate policies, to incentivise such third countries to follow the EU and join in on the goal of decreasing greenhouse gas emissions ("GHG"). CBAM can motivate companies and importers to choose sustainable suppliers. Companies with a global supply chain of goods comprised by CBAM should therefore evaluate their suppliers resident in third countries with less restrictions on GHG emissions.
To provide businesses and other countries with legal certainty and stability, CBAM will be phased in gradually and will initially apply only to the above-mentioned goods. In a transitional phase, a reporting system was applicable from 1 October 2023 until 31 December 2025, involving quarterly reporting of embedded emissions split into direct and indirect emissions, including an overview of any carbon price effectively paid abroad, as importers are entitled to a reduction in CBAM for any carbon price paid in the country of production (which is not rebated or otherwise compensated upon export). By 31 May each year, and for the first time in 2027 for the year 2026, the authorised CBAM declarant is obligated to report carbon emissions annually.
The charge will be settled through the purchase of certificates by importers. The price of the certificates will be determined by the EU Commission on an ongoing basis based on the weekly average auction price of EU Emissions Trading System (EU ETS) allowances expressed in €/tonne of CO2 emitted.
Who does it impact?
- Importers of goods covered by CBAM to the EU cleared for free circulation in the EU or stored for export to a third country for final consumption.
- Producers in third countries of goods covered by CBAM.
- When implemented in Norway; Importers of goods covered by CBAM to Norway / the EEA.
Status: In force
- The regulation of CBAM entered into force in the EU on 16 May 2023, and the transitional phase started on 1 October 2023 and continued until 31 December 2025. A permanent system for CBAM (CBAM Definitive Regime) entered into force in the EU on 1 January 2026 with quarterly reporting.
- The Norwegian Government aims to implement CBAM in Norway from 1 January 2027. On 24 October 2025, the Norwegian Government submitted a proposal for a new act for public consultation (the Norwegian CBAM Act). The bill implements Regulation (EU) 2023/956 (the CBAM Regulation) in Norwegian law, establishes powers to administer the CBAM Regulation via secondary legislation, and provides for transposition of expected delegated and implementing acts once they are incorporated into the EEA Agreement following consultations between EEA/EFTA states and the European Commission. The CBAM Act was adopted at first reading by the Norwegian Parliament on 8 June 2026. Implementing CBAM will also require changes to Norwegian customs legislation. The Government aims to implement the CBAM regime from 2027. After the Norwegian CBAM Act enters into force, only authorised operators will be entitled to import CBAM goods into Norway.. The application is submitted to the European Commission's CBAM portal (part of the CBAM registry) and is then processed by the Norwegian Tax Administration, which is the authorisation authority for the import of CBAM goods into Norway.
- On 10 September 2025, the European Parliament adopted simplifications to the CBAM, the so-called "Omnibus I", where the aim is to simplify and strengthen the implementation of CBAM by simplifying the sustainability reporting, targeting the companies that are more likely to have climate-damaging emissions, and not burdening smaller companies and occasional importers with minimal emissions. The amended law sets a mass-based threshold for importers importing less than 50 tonnes of goods in key sectors, which will exempt 90% of importers from the obligation to report under CBAM. The rules on imports still covered by the CBAM are also simplified, regarding, for instance, the authorisation process, the calculation of emissions, verification rules, and the financial liability of authorised CBAM declarants. The same simplifications will apply in Norway when CBAM is implemented. On 18 June 2025, the European Parliament and the Council reached an agreement on the Commission's proposal to simplify and strengthen CBAM. Immediately after the agreement was reached, the Commission conducted a public consultation from 1 July 2025 until 26 August 2025, where the aim was to gather opinions from relevant audiences on possible extensions of CBAM to downstream products (i.e., products that are further down the value chain of the goods currently in scope), anti-circumvention measures, electricity rules, and their potential impacts. The amended Regulation was officially published in the Official Journal of the European Union on 20 October 2025.
- In 2026, the Commission will further assess whether the scope of CBAM, i.e. the goods covered by CBAM, should be extended. The Norwegian CBAM regulations and the application of the rules will be affected by any changes adopted in the EU.
Relation to other initiatives and regulations
CBAM is an initiative pursuant to the Paris Agreement and shall complement EU ETS. The gradual introduction of CBAM is aligned with the phase-out of the allocation of free allowances under the EU ETS.
Thommessen's comments
The Norwegian Government supports the EU's implementation of CBAM, and has published a proposal for implementation of CBAM in Norway through a Norwegian CBAM Act. The Government aims to implement CBAM by 1 January 2027. Rules on applying for and granting authorised CBAM declarant status are planned to come into force earlier so entities can obtain authorisation prior to 2027.
The Ministry of Climate and Environment and the Norwegian Environment Agency will have the main responsibility for administering CBAM in Norway. The Customs Authority and the Norwegian Tax Administration will also have central roles in the administration of CBAM in Norway.
Under the Norwegian CBAM Act, operators importing goods covered by CBAM from third countries to Svalbard, the Norwegian continental shelf or the exclusive economic zone must register with the Norwegian Customs Authority to obtain a Norwegian identification number. The Norwegian identifier shall be used for the movement of goods to and from Norway. Operators that have goods movements to and from the EU must use the EU's EORI number. The requirement for a Norwegian identifier will therefore also apply to operators that are already registered with an EORI number for goods movements to and from the EU, and vice versa. This means that Norwegian or foreign operators importing CBAM goods into Norway and the EU must hold a Norwegian identification number for imports into Norway and an EORI number for imports into the EU.
Norwegian businesses importing goods to the EEA covered by CBAM should follow the legislative process, and consider the potential implications of CBAM for their business and measures to adapt and mitigate negative consequences to support the climate initiative and avoid unnecessary tax leakage. Please feel free to contact us if you have any questions in this regard.