CBAM enters the EEA Agreement: what the Joint Committee decisions change for Norway and Iceland

The EEA Joint Committee adopted two decisions on September 25, 2026 that bring CBAM into the EEA Agreement: Decision 283/2026 and Decision 287/2026. Together they incorporate Regulation (EU) 2023/956 and the Omnibus amendment, Regulation (EU) 2025/2083, into the agreement and settle how Norway and Iceland participate in the mechanism's IT systems and share its costs.

The immediate practical effect for EU importers is zero. Goods originating in Norway and Iceland were exempt from CBAM before September 25 and remain exempt after it. What the decisions change is who runs a CBAM, and where: Norway plans to operate the mechanism against its own third-country imports from January 1, 2027, and Iceland follows once its parliament approves the incorporation.

What Decisions 283/2026 and 287/2026 do

Decision 283/2026 incorporates Regulation (EU) 2023/956 and Regulation (EU) 2025/2083 into Annex XX (Environment) of the EEA Agreement, and Decision 287/2026 amends Protocols 10 and 31 to cover the technical and financial arrangements for Norwegian and Icelandic participation. The split follows the structure of the agreement itself. Annex XX is where EEA-relevant environmental law lives, while Protocol 10 governs the simplification of inspections and formalities in the carriage of goods and Protocol 31 governs cooperation in specific fields outside the four freedoms.

The table below separates the two decisions.

The Protocol 31 amendment matters because CBAM runs on EU systems that sit outside the EEA Agreement's normal scope. Under the arrangements described in the Council's accompanying documents, the two EEA EFTA states contribute financially to the operation of the CBAM Registry and the common central platform under Article 82 of the EEA Agreement and Protocol 32, and in return gain the right to access and use those systems for applying Regulation (EU) 2023/956. The Protocol 10 provisions on CBAM apply between the EU, Iceland and Norway.

Norway and Iceland are already exempt, so what actually changes?

Nothing changes at the EU border: goods originating in Norway, Iceland, Liechtenstein and Switzerland stay outside CBAM's scope under Annex III of Regulation (EU) 2023/956, and the Joint Committee decisions do not touch that exemption today. The exemption exists because all four countries either participate in or link to the EU ETS, so their goods already carry an equivalent carbon price. The Annex III mechanics are covered in the EU CBAM guide.

The change is institutional, and it runs in one direction: outward. Incorporation means Norway and Iceland take on the obligation to apply CBAM to their own imports from third countries, such as steel from China or fertilizers from Egypt, instead of remaining bystanders to the EU mechanism.

The Council documents accompanying the decisions describe the end state as a common CBAM area, in which the 50-tonne de minimis threshold of Article 2a applies jointly to imports into the EU and into the customs territories of the EFTA states that apply CBAM. The same documents state that EFTA states applying CBAM should no longer be treated as third countries under the regulation and should then be deleted from Annex III. That deletion is a consequence of the decisions entering into force and the countries actually applying the mechanism, not of the September 25 adoption itself.

Three things therefore do not happen now. EU importers of Norwegian aluminium or Icelandic ferro-alloys gain no new obligation. No certificates become due on EEA-internal trade. And Annex III keeps all four listed countries until the incorporation takes legal effect.

What Norwegian and Icelandic importers face

Norwegian importers of CBAM goods face a national mechanism planned to apply in full from January 1, 2027, with the first declarations due in 2028 for goods imported during 2027. Norway is furthest along. The Storting adopted a Norwegian CBAM Act in June 2026, and the Norwegian Environment Agency set out the operational chain in its September 25 notice. The preparatory steps for Norwegian importers are listed below.

• Register with Tolletaten, the Norwegian customs authority, and obtain a Norwegian CBAM identifier.
• Apply for authorization through Skatteetaten, the Norwegian tax administration, if annual imports of CBAM goods exceed 50 tonnes, or in every case for hydrogen and electricity imports.
• Watch for the opening of registration and authorization, which the Environment Agency says is planned for later this autumn.

Iceland sits one step behind. The Althingi must still approve the incorporation before CBAM can take effect there, so no Icelandic application date is fixed.

What happens next

The decisions are adopted but not yet in force: the EFTA EEA-Lex register records that entry into force "is pending fulfilment of constitutional requirements by Iceland, Liechtenstein and/or Norway pursuant to Article 103 EEA". Parliamentary approvals are the gating item, and Norway's June 2026 CBAM Act shows how an EEA EFTA state legislates the mechanism nationally in parallel.

Liechtenstein is the outlier among the three EEA EFTA states. It forms part of the Swiss customs territory under its 1923 Customs Treaty with Switzerland, and the participation arrangements in the decisions concern Iceland and Norway. Switzerland itself stays outside the construction entirely, exempt through its own ETS, which is linked to the EU ETS.

For EU compliance teams, the file is a watch item rather than a work item. The legal text that governs their obligations remains Regulation (EU) 2023/956 as amended, and the next scheduled change in their calendar is unaffected: certificate sales open on February 1, 2027, and the first annual declaration falls due on September 30, 2027. The date to watch on the EEA file is January 1, 2027, when Norway intends to switch its mechanism on.