No. Norwegian and Icelandic aluminium falls outside CBAM. Annex III of Regulation (EU) 2023/956 excludes countries in the EEA or linked to the EU ETS, so Norway, Iceland and Switzerland face no certificate obligation whatever their emissions. CBAM repricing therefore lands on in-scope suppliers such as China, Türkiye and the Gulf.
Why Norwegian and Icelandic aluminium is exempt
Annex III of Regulation (EU) 2023/956 places goods from Norway, Iceland and Switzerland outside the mechanism. Norway and Iceland participate in the EU ETS through the EEA, Switzerland runs a linked system, and producers there already pay an equivalent carbon price. The exemption follows from the origin’s carbon pricing regime, not its footprint; a listed origin stays exempt whatever its emissions. Origins not listed in Annex III shipping aluminium under CN codes 7601 to 7616 have faced the definitive regime since 1 January 2026.
Where the exemption leaves the EU import market
The exemption removes most of the top of the EU import market from CBAM’s reach. Eurostat puts 2024 EU imports of aluminium and articles (HS 76) at about EUR 29.5 billion, and Annex III splits the top five suppliers cleanly:
| Supplier | 2024 EU imports | Share | CBAM status |
|---|---|---|---|
| Norway | EUR 4.4 billion | 15% | Exempt (EEA / EU ETS) |
| China | EUR 3.9 billion | 13.1% | In scope |
| Türkiye | EUR 2.8 billion | 9.4% | In scope |
| Iceland | EUR 2.1 billion | 7.3% | Exempt (EEA / EU ETS) |
| Switzerland | EUR 1.7 billion | 5.8% | Exempt (linked ETS) |
Source: Eurostat, reference year 2024, HS 76.
Norway, the largest supplier, plus Iceland and Switzerland sit outside the mechanism, so certificate costs land on the in-scope suppliers that follow: China, Türkiye and the Gulf, with the UAE and Bahrain both material. A fuller ranking appears in the EU’s top aluminium suppliers under CBAM.
What the exemption means for in-scope exporters
In-scope exporters compete against exempt metal that is also among the lowest carbon available. Norwegian and Icelandic smelters run largely on hydropower; estimates from Hasanbeigi / ORF (2025) put direct intensity near 1.53 tCO2e per tonne for Norway and 1.59 for Iceland, against an estimated 2.28 for China and 1.75 for India. Aluminium is an Annex II good, so CBAM prices direct emissions only; the workable response is to demonstrate a low direct footprint rather than rely on defaults, covered for India in Indian aluminium default values. Steps for an in-scope exporter:
- Map each product to its CN code and the mechanism in the CBAM guide.
- Prepare installation-level emissions data for verification by an accredited verifier, since verified actuals usually undercut marked-up defaults.
- Scope the exposure and the data plan with a CBAM consulting service.
Sources: Regulation (EU) 2023/956 · European Commission, CBAM