Senseible

Do EU importers pay CBAM on aluminium from Norway or steel from Switzerland?

No. Annex III of the CBAM Regulation exempts goods originating in Iceland, Liechtenstein, Norway and Switzerland, because they apply the EU ETS or a linked system. An origin certificate is still needed, and goods only passing through these countries are not exempt.

Who is exempt

Origin, not shipping route

The exemption follows the non-preferential origin of the goods. Indian or Chinese metal routed through a Norwegian port or warehouse keeps its original origin and is covered.

What to keep

Origin documents for each shipment. If origin is unclear, customs will treat the goods as covered until it is shown.

What Senseible does here

Senseible keeps supplier documents dated and fingerprinted by shipment, so origin and emissions records can be shown together when an importer asks.

Sources: CBAM Regulation (EU) 2023/956, consolidated, European Commission, CBAM legislation and guidance

Last reviewed 2026-10-22.