CBAM in the EEA 2026: costs and obligations for importers with Norway, Iceland and Liechtenstein

Key data

If your company imports industrial products from Norway, Iceland or Liechtenstein, this decision directly affects you. Council Decision (EU) 2026/2240, published on 6 October 2026, approves the European position to incorporate the CBAM into the EEA Agreement, standardizing carbon rules throughout the European economic area. Until now, the CBAM was only mandatory in EU Member States; following this decision, Norway, Iceland and Liechtenstein fall under the same climate regulatory framework.

The practical result is clear: any import operation of the affected products with these three countries generates a new obligation to declare and purchase CBAM certificates. Ignoring it has real operational and economic consequences.

What does this regulation establish?

The CBAM is the EU's instrument to prevent "carbon leakage": that European companies buy products manufactured outside with lower climate requirements, thereby avoiding the cost of CO2. Its operation is straightforward: the importer must declare the CO2 emissions embedded in the imported product and acquire CBAM certificates equivalent to those emissions.

This decision extends that mechanism to the three EEA countries that are not EU members, modifying Annex XX (Environment) of the EEA Agreement. The affected products are as follows:

The regulatory logic is as follows: if an importer brings steel from Norway, they must declare how much CO2 was emitted to manufacture it and purchase the corresponding CBAM certificates. This equalizes the climate cost between the imported product and that manufactured within the EEA under the emissions trading system (ETS) regime.

Economic and operational impact

The economic impact depends on the volume of imports and the carbon intensity of the product. The regulation does not set a specific amount per certificate (that price is determined by the European carbon market), but it does establish the obligation to acquire them for each tonne of CO2 embedded in imported products.

The operational effects are immediate and concrete:

• New direct costs: purchase of CBAM certificates for each import of listed products from Norway, Iceland or Liechtenstein.
• New declaration obligations: importers must calculate and declare the CO2 emissions embedded in each imported shipment.
• Adaptation of internal processes: procurement, logistics and compliance departments must integrate CBAM into their workflows.
• Review of contracts with suppliers: it may be necessary to renegotiate terms with Norwegian, Icelandic or Liechtenstein suppliers to obtain product carbon footprint data.
• Competitive standardization: the measure eliminates the advantage that an importer operating with these three countries could have over one importing from outside the EEA, as all fall under the same rules.

For sectors such as construction (cement, steel), chemical industry (fertilizers), metallurgy (aluminum) or energy (electricity and hydrogen), the impact can be significant if Norway, Iceland or Liechtenstein are regular suppliers.

Who does it affect?

• Steel importers from Norway, Iceland or Liechtenstein.
• Cement importers from these three countries.
• Aluminum importers from these three countries.
• Fertilizer importers from these three countries.
• Hydrogen importers from these three countries.
• Electricity importers from these three countries.
• Exporters operating in these markets and needing to adapt their documentation and compliance processes.
• Carbon-intensive industrial sectors with supply chains that include suppliers in the non-EU EEA.
• CFOs and procurement directors managing industrial procurement costs with these countries.
• Customs and foreign trade advisors managing import declarations for their clients.

Practical example

Imagine a Spanish construction company that regularly imports structural steel from Norway. Until now, that operation did not generate CBAM obligations because Norway, although part of the EEA, was not included in the scope of the mechanism.

With the entry into force of this decision, the company must:

1. Request from its Norwegian supplier the data on CO2 emissions embedded in the supplied steel (tonnes of CO2 per tonne of steel).
2. Declare those emissions to the competent authorities in each import.
3. Acquire the corresponding CBAM certificates for the volume of CO2 declared.

The same scenario applies to an agricultural company importing fertilizers from Norway, or an energy company importing electricity or hydrogen from Iceland. In all cases, the new cost is the market price of the CBAM certificate multiplied by the tonnes of CO2 embedded in the imported product.

What should companies do now?

1. Audit your suppliers: identify if any of your regular suppliers are located in Norway, Iceland or Liechtenstein and if the products they supply you are on the CBAM list (steel, cement, aluminum, fertilizers, hydrogen, electricity).
2. Request carbon footprint data: contact your suppliers in these countries to obtain information on CO2 emissions embedded in their products. Without this data you will not be able to comply with the CBAM declaration.
3. Review your customs declaration processes: ensure that your import declarations incorporate the fields and data required by the CBAM.
4. Budget the cost of certificates: calculate the estimated economic impact based on your import volumes and the current price of the European carbon market.
5. Update contracts with suppliers: include clauses that require the supplier to provide verified emissions data, and assess whether the additional cost should be passed on to the purchase price.
6. Train your team: procurement, logistics and compliance departments must understand the new obligations to avoid declaration errors.

Official source

Consult full regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026D2240