MAFC in the EEA: what steel, cement and aluminum importers must do with Norway, Iceland and Liechtenstein

Key data

If your company trades with Norway, Iceland or Liechtenstein in high carbon footprint products, this decision affects you directly. The EU Council adopted, on 24 September 2026, the European position to integrate the Carbon Border Adjustment Mechanism (CBAM) into the EEA Agreement framework, published in the Official Journal on 8 October 2026 as Decision (EU) 2026/2256.

The objective is to extend to non-EU EEA countries the same payment obligations for embedded emissions that already apply to trade with third countries, and at the same time simplify customs controls and formalities for the transport of goods between the EU and these three countries.

What does this regulation establish?

The decision authorizes the EU to defend, in the EEA Joint Committee, the modification of two key protocols of the EEA Agreement:

• Protocol 10: On simplification of controls and formalities regarding the transport of goods between the EU and non-EU EEA countries.
• Protocol 31: On cooperation in specific sectors not included in the four freedoms, to which the financial contribution to the CBAM is added.

The CBAM requires importers of certain products to acquire CBAM certificates that reflect the price of carbon they would have paid if those goods had been produced under EU emissions standards. With this decision, that mechanism extends to trade with Norway, Iceland and Liechtenstein within the EEA framework.

The products affected by the CBAM are the following:

Economic and operational impact

The extension of the CBAM to the EEA has two simultaneous effects on Spanish companies:

• Additional cost for embedded emissions: Importers of the six listed products operating with Norway, Iceland or Liechtenstein must calculate and declare the embedded emissions in imported goods, and acquire the corresponding CBAM certificates. The cost will depend on the volume imported and the current price of carbon in the EU emissions trading market (ETS).
• Customs simplification: The modification of Protocol 10 seeks to reduce controls and formalities in the transport of goods, which can result in shorter transit times and lower logistics costs for operators already working with these countries.

For international logistics operators managing transits between the EU and non-EU EEA, the simplification of formalities is an opportunity for operational efficiency. For industrial sectors with high carbon footprint, the impact is mainly compliance and cost.

Who does it affect?

• Spanish companies that import steel, cement, aluminum, fertilizers, electricity or hydrogen from Norway, Iceland or Liechtenstein.
• Spanish companies that export these same products to those three countries and must anticipate the compliance requirements that their customers will impose on them.
• Logistics operators and freight forwarders that manage transport of goods between the EU and non-EU EEA.
• CFOs and procurement directors of industrial companies with supply chains that include suppliers from Norway, Iceland or Liechtenstein.
• Foreign trade advisors that manage customs declarations and regulatory compliance for clients with operations in the EEA.

Practical example

A Spanish construction company regularly imports structural steel from Norway. Until now, its CBAM compliance obligations were limited to trade with countries outside the EEA. With the integration of the CBAM into the EEA Agreement, this company must:

1. Request from its Norwegian supplier the data on embedded emissions in the supplied steel.
2. Calculate the number of CBAM certificates needed based on those emissions and the price of carbon in the European ETS.
3. Adapt its customs declaration processes to include the emissions information required by the CBAM.
4. Take advantage, at the same time, of the simplification of formalities provided for in the modification of Protocol 10, which can reduce times and costs at the border.

The same scheme applies to importers of cement, aluminum, fertilizers, electricity and hydrogen originating in Iceland or Liechtenstein.

What should companies do now?

1. Identify if your operations are affected: Check if you import or export steel, cement, aluminum, fertilizers, electricity or hydrogen with Norway, Iceland or Liechtenstein. If so, this regulation affects you directly.
2. Audit the supply chain: Contact your suppliers in these countries to obtain data on embedded emissions in the products they supply you. Without that data, you will not be able to correctly calculate your CBAM obligations.
3. Review customs declaration processes: Coordinate with your foreign trade department or freight forwarder to adapt declarations to the new CBAM requirements in the EEA context.
4. Evaluate the impact on costs: Estimate the cost of CBAM certificates based on your import volumes and the current price of carbon in the ETS. Incorporate this cost into your forecasts and price negotiations with suppliers.
5. Take advantage of customs simplification: Inform your logistics operator of the changes in Protocol 10 of the EEA Agreement to identify possible savings in transport formalities.
6. Monitor the process in the EEA Joint Committee: The adopted decision is the EU's position for negotiation in the Joint Committee. Monitor formal approval and the entry into force date to plan operational adaptation.

Official source

Consult complete 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=OJ:L_202602256