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CBAM in Norway: the 2027 timeline after the Omnibus simplification

11 May 2026 · Skarpix

Norway plans to implement the EU's Carbon Border Adjustment Mechanism (CBAM) from 1 January 2027, via incorporation into the EEA Agreement. The EU has been running CBAM in transitional form since 2023 and entered the definitive regime on 1 January 2026; Norway joins the definitive regime directly when the regulation is incorporated.

Two things have changed materially since CBAM was first announced. First, the EU's CBAM Omnibus simplification package, Regulation (EU) 2025/2083, which entered into force on 20 October 2025, significantly reshaped the operational regime: a 50-tonne annual exemption replacing the old €150-per-consignment exemption, certificate purchases postponed to early 2027, and the annual declaration deadline moved from 31 May to 30 September. Second, the Norwegian authority split is now clear: Miljødirektoratet (Norwegian Environment Agency) is the coordinating authority, with Skatteetaten (Tax Administration) and Tolletaten (Customs) in supporting roles.

This article walks the current state for Norwegian importers, with the dates and authority responsibilities as they stand in mid-2026.

Who's affected

CBAM applies to importers of goods in six product categories: cement, iron and steel, aluminium, fertilisers, hydrogen, and electricity. The mechanism prices the embedded carbon emissions of these goods at the EU ETS rate, with credit given for any carbon price already paid in the country of production. The goal is to prevent "carbon leakage", or production shifting to jurisdictions with weaker climate policy.

If you import any of these goods into Norway from outside the EEA, you're potentially in scope. The 50-tonne annual exemption (introduced by the Omnibus simplification) means that importers whose total annual net imports of CBAM goods are below 50 tonnes are fully exempt from all CBAM obligations, including reporting, authorisation, and certificate purchases. The European Commission estimates this exempts around 90% of importers while still capturing 99% of embedded emissions. Hydrogen and electricity are excluded from this threshold.

The Norwegian authority split

Three Norwegian agencies share CBAM responsibilities:

  • Miljødirektoratet (Norwegian Environment Agency) is the coordinating authority. It holds overall responsibility for the CBAM regulation, handles annual CBAM declarations, and is the agency to engage with on substantive questions about scope and reporting. Constitutional responsibility for CBAM has been transferred from the Ministry of Finance to the Ministry of Climate and Environment.
  • Skatteetaten (Norwegian Tax Administration) is responsible for authorising importers as CBAM declarants. Authorisation applications are submitted via the European Commission's CBAM portal and processed by Skatteetaten. Skatteetaten also handles penalty collection.
  • Tolletaten (Norwegian Customs Service) handles border control: verifying that importers of CBAM goods are authorised CBAM declarants and feeding the relevant customs data into the CBAM register.

The split matters because each agency will have its own communications, guidance, and contact points. For an importer's compliance programme, Miljødirektoratet is the primary anchor; Skatteetaten is your authorisation counterparty; Tolletaten is your border-control counterparty.

Key dates for Norwegian importers

  • 1 January 2027: CBAM enters into force in Norway, contingent on EEA incorporation. The Norwegian regulation (CBAM-forskriften) implementing the EU rules went through public consultation in early 2026.
  • 31 March 2026 (EU): Importers who submitted their authorisation application by this date were eligible to continue importing provisionally while their application was processed, even above the 50-tonne threshold. Norwegian transposition is expected to mirror this provisional-import mechanic for Norwegian importers.
  • 1 February 2027: CBAM certificate purchases open. Certificates cover the embedded emissions of CBAM goods imported during 2026. (No certificates are purchased in 2026 itself. This is one of the most material Omnibus changes.)
  • 30 September 2027: First annual CBAM declaration deadline. Covers 2026 imports. This is the date that moved from 31 May to 30 September under the Omnibus simplification.
  • Subsequently: 30 September each year for prior-year imports.

The 30 September deadline applies to both the annual CBAM declaration and the surrender of CBAM certificates. The certificate surrender requirement during the year was also reduced under the Omnibus from 80% to 50% of embedded emissions, providing more cash-flow flexibility for importers.

Action checklist

For Norwegian importers preparing now:

  1. Confirm scope. Check whether your imports fall under the six CBAM categories. The CN codes are in Annex I of the CBAM regulation.
  2. Quantify volume. Determine whether your annual net imports of CBAM goods sit below or above the 50-tonne threshold. Don't average across categories: the threshold is total CBAM goods.
  3. Plan for authorised declarant status if you're above the threshold. Authorisation is processed by Skatteetaten on behalf of the EU registry. Submit your application early.
  4. Build supplier emissions data flows now. The annual declaration requires verified embedded emissions data from your suppliers. This is the most operationally challenging part of CBAM for many importers and the easiest to underestimate.
  5. Engage an accredited verifier early. Verified emissions data is mandatory for the definitive regime declarations. The accredited verifier market is supply-constrained.
  6. Model the cash flow. Certificate purchases begin 1 February 2027 for 2026 imports. The reduced 50%-of-emissions in-year requirement helps but you still need a forecast.

How Skarpix can help

Skarpix's CBAM self-assessment walks Norwegian importers through scope confirmation, threshold check, authorisation path, supplier data planning, and verifier engagement. It produces a PDF report you can share with your finance team or board for the planning cycle.

Start the CBAM assessment or read more about CBAM in Norway at /cbam.