CBAM in Norway: ready for 1 January 2027
11 May 2026 · Skarpix
CBAM (Carbon Border Adjustment Mechanism) is the EU's carbon border adjustment mechanism. It prices the emissions from the production of imported goods from countries outside the EEA, so European industry is not undercut by producers in countries with weaker climate rules. In the EU the regulation enters into force on 1 January 2026. In Norway, the planned date is 1 January 2027 through incorporation into the EEA Agreement.
Three Norwegian authorities share the work. Miljødirektoratet is the lead and coordinating authority, and makes decisions regarding CBAM declarations and CBAM certificates. Skatteetaten authorises importers as CBAM declarants and collects administrative fines. Tolletaten controls at the border that importers of CBAM goods are authorised CBAM declarants.
Who is in scope
CBAM applies to importers of six categories of goods from countries outside the EEA: cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. Which specific goods fall under each category is determined by the CN codes in Annex I of the CBAM Regulation.
An important exemption: importers with total annual net imports below 50 tonnes of CBAM goods are fully exempt from all CBAM obligations. Hydrogen and electricity are kept outside this threshold and are in scope regardless of quantity. The 50-tonne exemption takes many small and mid-sized importers out of the regulation entirely. Check this first.
Timeline for Norwegian rollout
Autumn 2026: The application process for authorisation as a CBAM declarant is expected to open at Skatteetaten, once the Norwegian CBAM regulation is finalised. The Norwegian regulation went through public consultation with a deadline of 27 March 2026.
1 January 2027: CBAM enters into force in Norway. From this date, only authorised CBAM declarants can import CBAM goods into Norway. Tolletaten controls this at the border.
2028: The first annual CBAM declaration is filed. The declaration covers 2027 imports and contains verified emissions data for each consignment.
EEA incorporation is the precondition. The entire timeline depends on the CBAM Regulation being incorporated into the EEA Agreement. Work between the EEA/EFTA states and the European Commission is ongoing.
What CBAM requires, in practice
Authorisation. Before 1 January 2027, importers of CBAM goods must apply for and receive authorisation as a CBAM declarant. The application is submitted via the European Commission's CBAM portal and processed by Skatteetaten. Only authorised declarants are allowed to import CBAM goods after 1 January 2027.
Verified emissions data. For each consignment of CBAM goods, you must be able to document the embedded emissions from production, verified by an independent verifier. This is the technical core of CBAM, and often the hardest part for importers without a close relationship to the producer.
Annual declaration. By 30 September each year (starting in 2028 for 2027 imports), you submit a CBAM declaration that documents total import volume and total emissions for the previous year.
CBAM certificates. You purchase CBAM certificates matching the emissions from the previous year's imports, priced to mirror the EU emissions trading market. This is the mechanism that actually prices the emissions.
The underestimated work: supplier data
The part of CBAM that's easiest to underestimate is the data flow from suppliers. If you import steel or aluminium from a producer in Asia, you have to obtain verified emissions data from that producer, for the specific products you import, for every consignment.
That requires:
- A commercial relationship in which you can demand this
- A producer who actually knows the embedded emissions of their products
- A verifier accredited under EU rules
- A system to receive, store, and use the data
Many importers discover this only when the application process arrives. By then it's too late to build the relationships from scratch. Start the supplier conversations now.
Penalties
The primary risk is not fines, it's that you can't import. Tolletaten checks at the border that the importer of a CBAM good is an authorised CBAM declarant. If you aren't on 1 January 2027, the consignment is stopped.
On top of that, Skatteetaten can impose administrative fines for incorrect or incomplete CBAM declarations, or for missing authorisation. The levels will be set in the Norwegian regulation but are expected to be in line with the EU level.
What to do now
Scope check, first. Do you import any of the six categories of goods from countries outside the EEA? How much, in aggregate, per year? If you're under 50 tonnes net, and it's not hydrogen or electricity, you're exempt. Settle this first. It saves you significant work if the answer is that you're outside scope.
Identify the authorisation need. If you're in scope, you have to be authorised as a CBAM declarant before 1 January 2027. The application process is expected to open in autumn 2026. Use the months before to gather documentation.
Start the supplier conversations. This is the work that takes longest. Which of your suppliers can deliver verified emissions data? Which can't? What do you do with the ones that can't? Switch supplier, or negotiate a solution?
Build or buy the data flow. You need a system to receive emissions data per consignment, store it, link it to customs declarations, and use it in the annual CBAM declaration. This is a data flow you don't have today.
Track Miljødirektoratet. Miljødirektoratet publishes Norwegian CBAM updates continuously. It is the primary Norwegian source of information.
Skarpix offers a free CBAM assessment that takes 5-10 minutes and produces a concrete report: are you in scope, how big is the job, and what are the next practical steps. It's built around the Norwegian picture, including the three-authority model and the actual timeline.