The CBAM scheme to be introduced in 2027 for imports to Norway

The CBAM scheme will be introduced for the import of certain goods into Norway from 2027; see the Climate and Environment Ministry’s publication of the proposed legislation.

The purpose of the scheme is to create equal competitive conditions for industry within the EU/EEA and Switzerland regarding payment for emission requirements for certain goods. The CBAM tax is intended to ensure that countries where industry does not pay for emissions cannot bring these goods into the EU/EEA and Switzerland without paying a tax for such emissions.

The CBAM scheme applies to the import into the EEA area and Switzerland of certain types of goods such as cement, electricity, iron & steel, aluminum, hydrogen, and fertilizers.

Norwegian importers must, after January 1, 2027, be CBAM-registered and, in connection with this, purchase certificates for the greenhouse gas emissions associated with the goods. This scheme will be introduced in the EU from 2026.

Importers will have to purchase CBAM certificates from the responsible authority in their home country. The price of the certificates will be calculated based on a weekly average auction price for EU ETS allowances, expressed in euros per ton of CO₂ emissions.

The scheme applies to importers with more than 50 tons per year of CBAM goods imported from outside the EEA/EU and Switzerland. The scheme also does not cover goods originating within the EEA/EU and Switzerland.

For importers who can document that the carbon emissions from the production of the goods have already been compensated, the CBAM tax upon import can be adjusted accordingly.

For many importers, it will be difficult to obtain information about the emissions related to the imported goods. For these goods, possible reference emission values have been established, where information about the country of production is also used as a basis for calculating the CBAM tax.

Importers need to register as importers in a national register as well as in a common CBAM register managed by the EU Commission.

Norwegian industry has a high share of carbon-intensive production and goods import. Norway is currently part of the EU's emission trading system (EU/ETS), a scheme that has positively affected greenhouse gas emissions from product manufacturing within the EU. Free quotas are to be phased out as the CBAM fee is implemented and increased. This will impact Norwegian manufacturers and importers of goods from both EU countries and non-EU countries.

The goods covered by CBAM are linked to specific tariff numbers (HS) in the customs tariff.
 

It is, therefore, crucial to have a good understanding of the goods and how these goods should be classified under the customs tariff upon import to Norway. Today, this has not been crucial for many importers since most industrial goods are customs duty-free upon import to Norway. This will now change. Additionally, it is essential to be aware of where the goods are produced (country of origin) concerning emission calculations.

To make this technically more complex, there are specific, full, or partial exemption schemes available through customs procedures for temporary admission for processing of industrial goods (active processing), processing outside the customs territory (passive processing), and the re-importation of goods. Additionally, the emission calculation methodology is complex as both direct and indirect embedded emissions need to be calculated at product and installation levels.

The introduction of the CBAM tax and the phasing out of free quotas (EU/ETS) will impact Norwegian heavy industry, the structure of Norwegian fees, and the free quota system (CO2 quotas) for this sector.

Companies importing goods to Norway affected by the CBAM scheme are advised to start mapping whether their import goods may be subject to the CBAM tax from 2027.

To determine if the goods are covered by the CBAM scheme, it is essential to verify the use of the correct customs tariff number and the actual origin of the goods. KPMG can assist companies with such mapping, facilitating the process of purchasing CBAM certificates and meeting the emission reporting requirements.