Norway has been a member of the WTO since 1 January 1995 and a contracting party to the General Agreement on Tariffs and Trade (GATT) since 10 July 1948. Norway is also a party to several plurilateral trade agreements, including the Civil Aircraft Agreement, the Government Procurement Agreement, the Information Technology Agreement and the Pharmaceutical Agreement.
In addition, Norway has concluded numerous bilateral and multilateral agreements on trade facilitation and regulatory/co-operative controls. Norway is a member of the European Free Trade Association (EFTA) and, through the EEA Agreement, participates in the EU’s internal market.
Norway is party to numerous bilateral and multilateral free trade agreements. Most were negotiated through EFTA, although Norway has also concluded some agreements independently. The Norwegian Customs Authority (Tolletaten) maintains an up‑to‑date list of Norway’s free trade agreements and agreements under negotiation on the Norwegian Customs Authority’s website.
In 1971 Norway implemented the Norwegian Generalised System of Preferences (GSP) granting preferential tariff treatment – duty exemptions or reductions – to imports from developing countries. Norway co-operates with the EU, Switzerland and Turkey to harmonise the GSP rules of origin applied under the arrangement.
Norway is negotiating free trade agreements with Vietnam and China. It has concluded free trade agreements with Kosovo, Malaysia, Mercosur (Argentina, Brazil, Paraguay and Uruguay) and Thailand, and has renegotiated free trade agreements with Ukraine and Chile. All of these agreements are awaiting implementation.
Norway has entered a free trade agreement via the Trade and Economic Partnership Agreement (TEPA) between India and the EFTA states. TEPA was signed between the parties on 10 March 2024 and came into force on 1 October 2025.
By presidential proclamation of 31 July 2025 adjusting reciprocal tariff rates, the United States began imposing a 15% tariff on Norwegian goods from 7 August 2025. This tariff is in addition to ordinary MFN (most-favoured-nation) tariffs, with certain exceptions.
Following the Trump Administration’s imposition of higher tariffs on several Norwegian products in spring–summer 2025, Norway is negotiating with the US on an agreement that could affect tariff rules. The EU remains Norway’s main trading partner, but because Norway is not an EU member, any US–EU measures that change trade flows or introduce higher tariffs could also affect Norwegian exports to the EU, particularly if the EU applies tariff barriers from which Norway is not exempt. On 18 November 2025, the European Commission adopted definitive safeguard measures on imports of certain ferrous alloys (ferroalloys) into the EU. The measures apply to all third‑country suppliers and explicitly include Norway, meaning additional duties will also apply to Norwegian exports of those ferroalloys to the EU. The measures will remain in force for three years.
The Norwegian Customs Authority is the administrative body responsible for enforcing the regulatory framework for customs and the movement of goods into and out of Norway. It verifies that goods are correctly declared, determines and checks the basis for customs duties and rules of origin, and performs tasks on behalf of other agencies at the border. The Norwegian Tax Administration (Skatteetaten) is responsible for collecting customs duties, import VAT and other import‑related charges.
Decisions by the Norwegian Customs Authority may be appealed to the legal staff (juridisk stab) in its Legal Department (Rettsavdelingen). Decisions on customs duties, import VAT and other import charges are appealed to the Tax Appeals Board (Skatteklagenemnda) or the Norwegian Tax Directorate (Skattedirektoratet), depending on the matter. Administrative review may be followed by judicial appeal to the courts.
The Ministry of Finance (Finansdepartementet) sets customs policy, proposes and administers customs legislation and tariff schedules, and provides political and administrative oversight of the Norwegian Customs Authority.
The Norwegian Customs Authority is the primary agency responsible for customs administration and enforcement – it controls goods at the border, ensures correct declarations, enforces prohibitions and restrictions, administers duties and rules of origin, and issues customs decisions. Investigation and prosecution of smuggling and other customs-related criminal offences are handled by the Norwegian police and prosecuting authorities, including the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime (Økokrim).
Other authorities that enforce rules at the border or co-operate closely with the Norwegian Customs Authority, depending on the type of goods, are:
Norway does not have a single, standalone instrument comparable to the EU’s Trade Barriers Regulation or the US Section 301. Instead, Norway addresses harmful foreign trade practices through international dispute settlement (WTO, EEA/EFTA and free trade agreements) and, where appropriate, by applying trade‑remedy measures such as additional duties or temporary limits on unfair imports from non‑EEA countries.
Norwegian business may request the competent ministry to open an investigation and may report trade barriers to the Ministry of Foreign Affairs (Utenriksdepartementet). Reviews are initiated on a case‑by‑case basis in response to complaints or evidence, not on a fixed schedule. Foreign companies and governments may participate in trade‑remedy investigations as interested parties and may submit information in treaty disputes (only states, however, are formal parties in WTO/EEA dispute procedures). See sections 3. Sanctions to 7. Other Measures Affecting Production and Trade below for more details.
The authorities publish notices, findings and final decisions, and documents relating to WTO/EEA cases are publicly available. Norway applies trade remedies sparingly; automatic agricultural special safeguards may apply to specific tariff lines when trigger conditions are met. Any measures in force are product and country‑specific. The current list of measures and applicable tariff lines is available from official ministry and Norwegian Customs Authority publications.
The Norwegian Customs Authority has been implementing new and improved systems across its control processes. A solution called Digitoll has been developed to serve as the primary channel for importing goods into Norway, facilitating faster border crossings for businesses and more effective controls for authorities. Under Digitoll, information on goods and transport must be submitted to customs digitally no later than at the point of border crossing, thereby streamlining customs processing and clearance. During 2025 the Customs Authority co-operated with the business community to promote large-scale adoption of Digitoll and submitted proposals to amend customs legislation to reflect digitalisation.
Digitoll will become mandatory and will be implemented gradually in accordance with deadlines set by the Customs Authority. Relevant implementation deadlines are as follows:
The CBAM Regulation
In line with European and Norwegian climate policy, the Norwegian government has proposed an Act on Carbon Border Adjustment Mechanism (the “CBAM Act”) to apply carbon pricing to imports into the EEA. The Bill implements Regulation (EU) 2023/956 (the “CBAM Regulation”) in Norwegian law, establishes powers to administer the regulation via secondary legislation, and provides for transposition of expected delegated and implementing Acts once they are incorporated into the EEA Agreement following consultations between EEA/EFTA states and the European Commission. Implementing CBAM will also require changes to Norwegian customs legislation.
CBAM aims to prevent carbon leakage from the EEA by ensuring that emissions embedded in certain imported goods are priced on the same basis as emissions from domestic production. Carbon leakage refers to the relocation or replacement of production, investment, activity or emissions to countries with less ambitious climate policies and lower carbon pricing. CBAM also seeks to encourage non‑EEA countries to reduce emissions by requiring importers to pay a carbon price equivalent to the EU Emissions Trading Schemes (ETS) allowance price for the emissions from the production of the imported goods. The mechanism covers goods in the cement, electricity, fertiliser, iron and steel, aluminium and hydrogen sectors. Importers whose CBAM imports exceed a specified aggregate threshold must obtain authorisation as a CBAM declarant and will be required to surrender CBAM certificates corresponding to the emissions from the production of those goods in third countries.
The Bill was published for consultation in October 2025, with a consultation deadline of 2 January 2026. The government aims to implement the CBAM regime from 2027. Rules on applying for and granting authorised CBAM declarant status are planned to come into force earlier, so entities can obtain authorisation prior to 2027.
At present, Norway does not impose any of its own sanctions. Instead, the Norwegian sanctions framework is founded on UN Security Council sanctions, which Norway is obliged to implement under international law. In addition, Norwegian policy is generally to incorporate EU restrictive measures. Norway has adopted most EU measures, with a few exceptions.
Norway’s sanctions framework is established by the Sanctions Act (Sanksjonsloven), and the individual sanctions regimes are implemented through various sanctions regulations. At present, Norway has approximately 30 sanctions regulations.
The Norwegian Ministry of Foreign Affairs has overall responsibility for setting and articulating Norway’s sanctions policy.
With respect to sanctions, the ministry decides whether Norway should adopt measures beyond those adopted by the UN Security Council and is responsible for changes to existing regimes and for the domestic legal framework, including interpretative matters and implementing legislative amendments. The ministry submits proposals to the government, issues regulations for new or amended sanctions regimes, and makes ministerial decisions on listings.
Norway’s national authority, the Directorate for Export Control and Sanctions (DEKSA), is responsible for implementing sanctions and restrictive measures in line with international obligations, and DEKSA also reports any suspicion of a breach to the Police Security Service (Politiets Sikkerhetstjeneste or PST).
Other agencies involved in administering and enforcing the sanctions regime include:
The Norwegian sanctions regime applies, as a general rule:
No persons, groups or entities are sanctioned solely by Norway at the present time. Norway implements sanctions against listed persons and entities in line with its international obligations and in accordance with sanction regimes to which Norway has acceded. The UN Consolidated List, which includes all persons and entities subject to UN Security Council sanctions, has been fully implemented in Norwegian law. Moreover, Norway has implemented most EU listings. These listings are incorporated into Norwegian law by decisions of the Ministry of Foreign Affairs, either by ministerial decision or by royal resolution.
As noted above in 3.5 List of Sanctioned Persons, Norway is legally obliged to implement UN Security Council sanctions and also enforces various restrictive measures adopted by the EU. The scope of these sanctions regimes varies significantly and is determined based on the applicable regulations. Norway currently enforces comprehensive sanctions against Russia and Belarus, aligned with the corresponding EU sanctions regimes. An updated list of country and territory‑specific sanctions regimes is available on DEKSA’s website.
In addition to the regimes noted above, Norway has implemented thematic sanctions regimes on cyberattacks, human rights violations, and chemical weapons. These measures have been adopted pursuant to the corresponding EU regulations and implemented domestically.
Norway does not impose secondary sanctions. There has been discussion of the EU’s sanctions packages and whether the EU should introduce secondary sanctions to strengthen the sanctions regime’s anti-circumvention rules. To the extent such measures are adopted by the EU in future packages, it is likely that corresponding provisions will be implemented in the Norwegian sanctions regime.
According to Section 4 of the Sanctions Act, individuals and entities can be subject to criminal liability for violating sanctions regulations. Intentional breaches may lead to fines, imprisonment for up to three years, or both. Negligent breaches may lead to fines, imprisonment for up to six months, or both.
Aiding and abetting are also punishable, and certain sanctions regulations, such as those relating to Russia, prohibit intentional participation in activities that have the purpose or effect of circumventing the sanctions regime.
Some sanctions regulations contain the possibility to apply for authorisation or exemption for activities that are otherwise prohibited. The purposes and conditions for obtaining such authorisations and exemptions are set out in the respective sanctions regulations.
Sanctions compliance has been receiving additional attention in Norway, particularly following the extensive measures imposed against Russia after its invasion of Ukraine. Public authorities have strengthened their enforcement efforts, and expectations regarding private-sector compliance have increased. Under Norwegian regulations, both individuals and entities are expected to act with due diligence, which in practice entails a requirement to conduct risk-based due diligence.
Many private companies have enhanced their compliance programmes to mitigate sanctions risk, as non-compliance can have significant consequences. In addition to regulatory exposure, companies may also face operational and reputational risks.
To date, there have been few prosecutions, and most cases have been resolved through penalty notices, which are only made public if they are not accepted and the case proceeds to a formal criminal trial. However, in a notable case, a Norwegian bank was held liable for breaching asset-freeze provisions. The court emphasised the importance of having adequate sanctions compliance systems in place. There is also currently increased focus on cases involving the circumvention of sanctions.
Given the rapidly evolving and expanding sanctions landscape, further regulatory and enforcement activity is expected.
Norway has implemented freezing obligations in line with UN and EU sanctions. Anyone who freezes funds or other assets must promptly notify and co-operate with DEKSA. DEKSA may share reports with the Financial Supervisory Authority of Norway, the PST and the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime.
In the sanctions regulations regarding Russia, there are also certain notification and reporting obligations, including those relating to sectoral sanctions, such as in connection with the sale of tankers.
Norway has no general blocking statute or anti‑boycott law that prohibits Norwegian individuals or companies from complying with third‑country (extraterritorial) sanctions. However, Norwegian entities remain bound by Norwegian law and must ensure that any compliance with foreign measures does not conflict with obligations implemented under Norwegian law, eg, domestic sanctions or export‑control rules.
One of the key developments in the past 12 months was the establishment of DEKSA in January 2025. Prior to this, responsibility for sanctions and export control matters was handled directly by the Ministry of Foreign Affairs.
As mentioned in 3.11 Compliance, a Norwegian bank was recently found by the court to have violated the asset-freeze obligations concerning an individual listed on the UN’s ISIL (Da’esh) and Al-Qaida Sanctions List. The court noted, among other things, that the bank has an independent responsibility to ensure proper compliance with the sanctions regulations, and that it must be adequately staffed to fulfil this obligation. This responsibility rests with the bank’s management and board of directors.
During the last 12 months, Norway has implemented regulations corresponding to the EU’s 15th, 16th, 17th and 18th Sanctions Packages.
Norway continuously implements EU sanctions against Russia, and it is expected that the EU will continue to adopt additional sanctions packages against Russia.
Norwegian export control is largely based on the corresponding EU framework. Detailed provisions governing Norwegian export controls, including licensing requirements, control lists and related obligations, are set out in the Export Control Act (Eksportkontrolloven) and the Export Control Regulation (Eksportkontrollforskriften).
As a general rule, all exports from Norway must be documented in an export declaration under the Movement of Goods Act (Vareførselsloven) and its regulations.
In addition, certain exports of goods, technology and services require a licence issued by DEKSA. Controlled items are listed in the three annexes to the Export Control Regulation, covering military products, dual-use items and strategic goods and technology. The first two correspond to the EU Common Military List and the EU Dual-Use List, respectively. The third is a national list covering critical or emerging technologies.
Additionally, in specific cases, a licensing requirement may be triggered for goods or technologies that are not listed. These specific cases are referred to as “catch-all” provisions or general clauses (see Section 7 of the Export Control Regulation). These includes goods, technology and services that may be used in connection with weapons of mass destruction or missiles, exports for military use in embargoed or conflict-affected areas, and exports that could enhance a state’s military capabilities in ways contrary to Norway’s significant security and defence interests.
Control of defence-related exports is based on national policy and is administered in accordance with the framework conditions set by the Norwegian parliament and policy prepared by the Ministry of Foreign Affairs.
DEKSA is the national authority responsible for export control in Norway, and it issues export licences for export-controlled goods, services and technologies. See 3.2 Legal or Administrative Authorities Imposing Sanctions. The Ministry of Foreign Affairs is responsible for Norwegian export control policy, legislation and guidelines.
The Norwegian Customs Authority enforces export control legislation at the border, checking that controlled items are properly licensed, and it conducts targeted checks to find illegal imports and exports under export‑control and sanctions regimes, in co-operation with DEKSA and the PST. The PST investigates and prosecutes breaches of Norwegian export controls.
The Norwegian export control regime applies to any natural or legal person who intends to export goods, services or technology subject to the export control regulations.
Norway does not maintain lists of restricted persons under the export control regulations. However, exports to individuals or entities listed on sanctions lists are restricted, and the sanctions regulations also impose additional export restrictions that must be taken into account when exporting goods, services or technology.
At present, Norway does not maintain any lists of sensitive exports beyond those described in 4.1 Export Controls.
As noted in 4.1 Export Controls, in Norway, export control includes so-called “catch-all” provisions, or general clauses, set out in Section 7 of the Export Control Regulation. These provisions specify four circumstances in which a licence requirement may be triggered for goods, services and technology not listed in the annexes.
Other types of export restrictions may apply to the following goods:
Additionally, as noted in 4.5 Restricted Persons, the sanctions regulations impose further export restrictions that apply to a range of goods.
Individuals and companies can be subject to criminal liability for breaches of the Norwegian export control regime. Unless the act is subject to stricter criminal provisions, any person who intentionally breaches the export control regulations could face fines, imprisonment for up to five years, or both. Negligent violations are punishable by fines or imprisonment for up to two years.
Any person who wants to export goods, technology or services subject to export controls from Norway must obtain an export licence by applying to DEKSA. The export control legislation does, however, contain certain exemptions from the licence requirement where specified conditions are met (see Section 8 of the Export Control Regulation).
Exporters are expected to implement robust compliance programmes and to exercise due diligence in connection with all exports, which entails assessing whether goods, services or technology are subject to export control requirements, obtaining the necessary licences, and ensuring that all exports are conducted strictly in accordance with the terms of the licences obtained.
As noted elsewhere, both intentional and negligent breaches of export control, customs and sanctions rules can lead to administrative sanctions, civil liability and criminal prosecution.
All exports of defence-related goods on List I must be reported quarterly to DEKSA using the prescribed form.
DEKSA was established in January 2025. Prior to that, responsibility for export control and sanctions matters was held by the Ministry of Foreign Affairs.
In a relevant key development in August 2025, the Ministry of Foreign Affairs published amendments to the Export Control Regulation, together with an accompanying guidance document,strengthening control of the export of technology.
Increased focus on technology transfer is anticipated in the coming period, driven by the recent regulatory amendments and accompanying new guidance.
The Ministry of Finance decides on the imposition of trade measures.
Trade measures may be tariff‑based, involving the suspension of tariff‑concession obligations and the imposition of a specific duty on the product in addition to any ordinary customs duty; or non‑tariff in nature, such as import bans, quantitative restrictions (quotas), price undertakings or similar measures.
The rules on trade remedies are set out in Chapter 13 of the Movement of Goods Act and are aligned with WTO obligations. Applicable measures include anti‑dumping, countervailing, safeguard and retaliatory measures, as well as special safeguard measures for agricultural products.
The primary authorities are the Ministry of Finance and the Norwegian Customs Authority. The government (the King in Council) adopts AD/CVD and safeguard measures based on assessments and proposals from the Ministry of Finance. Administration of special safeguard measures for agricultural products is assigned to the Ministry of Agriculture and Food (Landsbruks og matdepartementet). The Norwegian Customs Authority is responsible for border enforcement and for collecting anti-dumping and countervailing duties, in co-operation with the Norwegian Tax Authorities where relevant.
Cases concerning the imposition of trade remedies in the form of anti‑dumping and countervailing measures are normally initiated on the basis of a complaint to the Ministry of Finance by or on behalf of domestic industry.
Domestic companies may petition the authorities on an ad hoc basis. Trade remedy reviews are not conducted on a fixed schedule but are opened case by case in response to complaints, requests from third countries, or, in certain circumstances, on the authorities’ own initiative.
Any person who imports, manufactures, processes or trades goods of the same or a similar kind to those subject to potential trade remedies is entitled to submit observations in connection with the review. Foreign (non-domestic) operators may likewise participate.
Initiation of a Case
Norway’s trade remedy process for anti-dumping (AD), countervailing duties (CVD) and safeguards is case by case and aligned with WTO rules. Cases are normally initiated by a complaint from or on behalf of domestic industry, but AD measures may also be undertaken at the request of a third country or, in certain circumstances, on the authorities’ own initiative.
Presentation of Evidence
The complainant must provide evidence supporting the complaint. If the required evidence is not supplied, the complaint may be rejected as insufficiently reasoned. The Ministry of Finance conducts an admissibility check to determine whether the prima facie evidence of dumping or subsidisation, material injury and causation is sufficient. If so, a formal investigation is opened and interested parties are notified.
Investigation Phase
The investigation phase typically includes questionnaires and information requests to exporters, importers, producers and other stakeholders, on‑site verifications where needed, analysis of sales, price, cost, production and subsidy data, and disclosure of essential facts and calculations to affected parties, who are given an opportunity to comment. AD/CVD investigations are normally completed within one year or, in any event, within 18 months of initiation.
Imposition of Duties
Following the investigation, the ministry issues a recommendation and the government decides whether to impose, modify or lift measures. AD/CVD must not exceed the calculated dumping margin or the determined subsidy amount. Specific exporters may be excluded by price undertakings or by renunciation of subsidies.
Provisional measures may be imposed only after formal investigations have been initiated and announced and no sooner than 60 days after initiation. Provisional anti-dumping measures are normally limited in duration (generally up to four months, with limited extensions in specified circumstances), and provisional countervailing measures may not exceed 120 days. Provisional safeguard measures may be imposed for up to 200 days. There must be at least two days between the announcement and implementation/entry into force of a measure.
AD/CVD measures typically expire after five years unless a review shows that dumping or subsidy and injury continue or are likely to recur. Safeguard measures are normally limited to a maximum of four years unless it is subsequently determined they remain necessary.
The Ministry of Finance publishes reports of findings from trade‑remedy investigations and its recommendations on duties and safeguards. These reports and related announcements are available on the ministry’s website; formal decisions are implemented by regulations or other legal instruments published on Lovdata (the official register of Norwegian legislation).
Investigations, reports and decisions relating to special safeguard measures for agricultural products are handled and published by the Ministry of Agriculture and Food and/or the Norwegian Agriculture Agency (Landbruksdirektoratet). Enforcement and practical information (eg, collection of duties and customs notices) are published by the Norwegian Customs Authority.
No jurisdiction is categorically immune from AD/CVD or safeguard measures under Norwegian law. In principle, Norway may impose trade remedy measures against imports from any country. However, the scope for such measures is constrained by Norway’s international obligations, most importantly WTO rules, and by treaty commitments, for example under the EEA/EFTA framework and specific free trade agreements, which can limit the measures that may be taken, impose procedural requirements, or require consultations and compensation.
AD/CVD measures are subject to a mandatory review before expiry, normally after five years, and will lapse unless a review shows that dumping/subsidy and injury have continued or are likely to recur. Safeguard measures are time limited, normally up to four years, and must be reviewed before expiry. Provisional and interim reviews can also be initiated earlier on request or by the authorities.
Reviews of AD/CVD duties and safeguards are conducted by the Ministry of Finance and follow WTO-consistent procedures. Reviews may be requested by interested parties or initiated by the ministry. The ministry first assesses admissibility and, if warranted, opens a formal investigation.
The investigation gathers evidence (through questionnaires, verifications and submissions from exporters, producers and importers), discloses essential findings for comment, and may be accompanied by provisional measures. The ministry issues a recommendation, and the government decides whether to impose, modify or lift measures.
Trade remedy measures may be challenged before the ordinary courts, with Oslo District Court as the court of first instance. The court is required to expedite such proceedings.
Irrespective of the availability of judicial review in AD measures, affected parties may also appeal procedural decisions made during the administrative proceedings to the superior administrative authority, in accordance with the ordinary rules of administrative law.
There have been no significant changes over the last 12 months.
No significant changes are currently pending in this area.
The Security Act (Sikkerhetsloven) is the legal basis for Norway’s investment‑screening regime. The purpose of the Norwegian screening regime is to exercise oversight of ownership in companies that are of special significance to national security. Through the screening regime, the authorities’ aim is to identify and prevent investments that may pose a “not insignificant risk” of a threat to national security. The duty to notify is triggered by acquisitions of a qualified ownership interest in an undertaking which has been made subject to the regime (see 6.3 Transactions Subject to Investment Security Measures).
Where an investment falls within the Security Act’s scope, the prospective acquirer has a mandatory notification duty. The authority receiving the notification must inform the notifier within 60 working days whether the acquisition is approved, or will be referred to the King in Council.
If an acquisition might present a “not insignificant risk” of a threat to national security interests, the King in Council may decide that the acquisition will not be implemented, or that implementation will be subject to conditions. This applies even if an agreement has been entered into in relation to the acquisition.
Moreover, the Norwegian government also holds a broad golden power outside the formal filing regime. This golden power gives it the authority to intervene in any planned or ongoing activities, including acquisitions, that pose a “not insignificant risk” of a threat to national security.
Primary responsibility for administering and enforcing investment security measures lies with the relevant sectoral ministry, which handles notifications for companies within its remit. Where a proposed acquisition does not fall within any ministry’s area of responsibility, the case is referred to the Norwegian National Security Authority (Najonal sikkerhetsmyndighet or NSM). The final decision to intervene in a transaction must be made by the King in Council.
The current screening regime under the Security Act applies only to acquisitions of qualified ownership interests in entities that have been individually designated as subject to the Act or to its filing regime.
The filing obligation is triggered by the acquisition of a “qualified ownership interest” in the undertaking. As of November 2025 (see 6.9 Pending Changes to Investment Security Measures for more details), a “qualified ownership interest” is defined as an acquisition that directly or indirectly results in the acquirer obtaining:
Notification must be submitted by the prospective acquirer. Neither the seller nor the target company is subject to the notification obligation (however, see 6.9 Pending Changes to Investment Security Measures for more details).
There are no broad, automatic exemptions in the Security Act that categorically exclude particular countries, actor groups or sectors. That said, the filing regime is limited to the undertakings that have specifically been brought within the scope of the screening regime and includes specific thresholds; see 6.3 Transactions Subject to Investment Security Measures.
It is a criminal offence to intentionally or negligently breach any prohibition or order issued by the King in Council in connection with a transaction.
There is generally no separate statutory processing fee for investment‑screening notifications under Norway’s Security Act.
There have been no changes of significance to the rules governing investment security during the last 12 months.
Amendments to the Security Act on ownership restrictions were adopted in June 2023 and are expected to take effect in 2026. The changes will:
The government is also considering a proposal to regulate the notification scheme for foreign investments in a separate, standalone law. A government-appointed committee submitted a proposal for such legislation in December 2023.
Norway uses a mix of direct subsidies, tariffs and safeguard measures (notably, special safeguards for agricultural products), state grants and loan schemes, tax incentives, and targeted public‑procurement and state‑ownership policies to support domestic production and competitiveness.
Most measures aim to promote domestic value creation, R&D and the green transition rather than to restrict imports. All measures must comply with Norway’s international obligations under the EEA and the WTO, including EEA state aid rules (enforced via the EFTA Surveillance Authority) and the WTO Subsidies Agreement.
Norway implements both voluntary standards – Norwegian Standards (NS) and harmonised European standards (EN) – and mandatory technical regulations across sectors. While these measures primarily target safety, health, environmental protection and performance, mandatory references to standards and conformity assessment requirements can indirectly advantage suppliers already integrated within Norwegian testing, certification and regulatory practices.
Notable examples include building technical regulations (“TEK17”), which set detailed construction and energy requirements; maritime and offshore standards enforced by the Norwegian Maritime Authority (Sjøfartsdirektoratet) and Norwegian Ocean Industry Authority (Havindustritilsynet); and strict sanitary and phytosanitary (SPS) measures, labelling and traceability rules for food overseen by the Norwegian Food Safety Authority (Mattilsynet). Energy and eco‑design rules, together with state support (eg, Enova), further incentivise domestic low‑emission solutions.
Public procurement and sectoral licensing or concession regimes (energy, telecoms, petroleum, aquaculture, etc) can also promote domestic production through non‑discriminatory technical and sustainability criteria or through licence conditions that favour local capability and compliance.
Norway’s sanitary and phytosanitary requirements are intended to protect human, animal and plant health rather than to shield domestic industry. However, in practice, some measures can restrict certain imports. For example, seasonal or species‑specific restrictions, high testing or certification costs, and limited access to approved laboratories or approved establishments increase the compliance burden on foreign suppliers and advantage well‑prepared domestic producers.
This effect is particularly pronounced for imports from outside the EU/EEA, since Norway largely aligns its SPS rules with EU standards. All SPS measures must be scientifically justified, non‑discriminatory and proportionate under EEA/WTO rules.
Norway does not use competition law to restrict imports or favour domestic producers. The Competition Act (Konkurranseloven) enforced by the Norwegian Competition Authority (Konkurransetilsynet) is neutral and aligned with EEA rules. It targets cartels and abuses of dominance, not trade protection. Price regulations are limited and sector specific, and are applied primarily for other public interest reasons. Examples include rules in the agricultural sector, medicine pricing and reimbursement schemes, and the alcohol policy.
Norway does not use state trading or state‑owned enterprises as deliberate instruments to restrict imports. EEA and WTO obligations require neutrality, non‑discrimination and commercial conduct by state actors. State‑owned companies operate commercially and remain subject to applicable public‑law constraints and international commitments.
One notable exception in practice is agriculture. Statutory producer co-operatives (for example Tine in dairy and Nortura in meat/eggs), operating alongside the Norwegian Agriculture Agency, have market‑management roles. They administer supply measures and handle tariff‑rate quotas and import licences to stabilise the domestic market and support Norwegian production – actions taken within Norway’s WTO and EEA commitments.
Norway does not use “buy national” or “buy local” requirements in public procurement. Norwegian procurement rules mirror the EU/EEA directives and require equal treatment and non-discrimination, so contracting authorities may not favour Norwegian-origin or impose local-content requirements. Authorities may, however, include environmental, social, innovation or quality criteria (eg, low-emission performance, animal welfare standards or delivery times), provided these criteria are origin neutral and proportionate and that foreign suppliers offering equivalent solutions are accepted.
An exception applies in the defence and national security sector. Major acquisitions may include industrial co-operation or offset commitments that direct work, investment or technology transfer to Norway on national security or strategic industrial grounds.
Norway protects geographical indications (GIs) for agricultural products, foodstuffs and spirit drinks under a national scheme equivalent to the EU’s PDO/PGI/TSG. The scheme is administered by the Ministry of Agriculture and Food with implantation and oversight roles for the Norwegian Food Safety Authority and the quality body Norsk Mat.
These protections are not intended to restrict imports or block competing foreign products. They prevent only the use of protected Norwegian names for products that do not meet the registered product specifications.
Refer to the sections above for relevant issues and recent developments. Also refer to Norway Trends and Developments.
Introduction
Norway enters 2026 with a unique trade position: it operates an open, export-driven economy that is deeply integrated with the European single market through the European Economic Area (EEA) Agreement, yet remains outside both the European Union’s customs union and its common commercial policy. This hybrid arrangement offers Norway significant opportunities, including tariff-free access for most industrial goods and broad regulatory alignment with the EU. At the same time, it brings added complexity, such as duplicate border procedures, parallel compliance requirements, and limited influence over trade policies shaped in Brussels, Beijing or Washington.
Looking ahead, Norway’s trading environment will be shaped by three significant factors: a sharper focus on security policy and sanctions enforcement, the growing global urgency around energy transition and critical-mineral supply chains, and the phased introduction of the EU’s Carbon Border Adjustment Mechanism (CBAM). Norwegian companies that succeed in managing origin strategy, ESG compliance, digital traceability, and dual-regime obligations will be positioned to take advantage of Norway’s strong reputation for reliability and its distinct low-carbon profile.
Trade Architecture and Norway–EU Relationship
Norway participates in the four freedoms (goods, services, capital, persons) through the EEA and incorporates most internal market legislation. However, the EEA does not include the EU customs union or the common commercial policy, nor does it fully cover agriculture and fisheries, and foreign and security policy. The result is access to the single market, but no seat in EU trade negotiations or trade‑defence decisions.
This semi-detached status creates several layers of complexity for Norwegian businesses. Full customs formalities – including safety and security filings and origin documentation – apply to trade with the EU, making the management of clean master data and readiness for systems like the EU’s Import Control System 2 crucial as it becomes fully operational by 2026. Norway’s own Digitoll system will similarly become mandatory, underlining the need for robust data infrastructure and process integration across the supply chain.
From a policy perspective, Norway’s exclusion from the customs union means it sets its own external tariffs and manages its own trade defences towards non-EU partners such as the US, UK and China. This can create both opportunities and vulnerabilities: if, for example, the EU and US escalate a trade dispute, Norwegian companies may suddenly find themselves bound by new compliance requirements or shifts in tariffs, often with little advance notice.
This, together with security considerations, periodically revives debate over EU membership. However, public support for accession remains insufficient in the near term, and policy is likely to continue focusing on deepening EEA alignment and practical co-ordination with Brussels.
Security Policy, Export Control and Sanctions
Security has become central to trade policy. Norway is taking steps to bolster the resilience of its critical infrastructure (including energy assets, ports, and subsea cables), tighten foreign investment rules for sensitive sectors, and expand export controls covering advanced electronics, manufacturing technology, and international R&D partnerships. Businesses now face more intensive end‑use checks, partner screenings, and in some cases, licence requirements for cross-border research or data exchange.
Norway’s sanctions regime is largely harmonised with the EU and implemented through national law. It has grown in scope to address risks related to Russia, Belarus and Iran, as well as certain technology exports to China. Regulatory attention has pivoted sharply towards detecting and deterring circumvention – including monitoring re-exports via third countries, tracking trans-shipment, scrutinising maritime services for sanctions compliance, and increasingly, verifying beneficial ownership and vessel location data.
The practical takeaways for businesses are clear: whether engaged in shipping, offshore services or distribution, firms must now prioritise the incorporation of sanctions clauses, ensure auditability, and retain the flexibility to exit high-risk relationships quickly. Norway’s commitment to high alignment with EU measures, and close transatlantic co-ordination, means domestic exemptions are reserved only for essential cases – primarily energy, fisheries, or humanitarian needs.
Rules of Origin and “Tariff Frontiers”
Rules of origin present a significant challenge, especially given Norway’s tight integration into EU value chains. Norwegian components often end up in EU-origin goods exported to the US. As a result, if the US imposes tariffs on EU goods, Norwegian inputs could inadvertently become subject to US trade policy – even if Norway itself is not the direct target.
There is also asymmetry in trade retaliation: Norway is neither obliged nor automatically able to mirror EU countermeasures against US tariffs. This can create a “tariff frontier” at Norway’s borders: US goods might face EU tariffs, but not Norwegian ones, potentially diverting trade flows and exposing Norway’s market to sudden competitive pressures or scrutiny over circumvention into the EU.
The impact varies by sector. Industrial goods largely benefit from EEA access, but fisheries and agriculture – excluded from the EEA – face direct tariffs and quotas in both the EU and US markets. Metals face similar challenges; for example, US Section 232 tariffs on steel and aluminium have hit major Norwegian producers. Even when US tariffs are labelled “EU-specific”, the real-world integration of supply chains and anti-circumvention efforts mean Norwegian companies bear significant compliance burdens and risk delays.
The latest development here is the European Commission’s safeguard measures on ferrous alloys (ferroalloys), implemented on 18 November 2025. The safeguard imposes tariffs on Norwegian-produced ferroalloys for the EU market, potentially in violation of the EEA Agreement. The measures are in force for three years.
CBAM and Carbon‑Related Trade Instruments
The EU’s Carbon Border Adjustment Mechanism (CBAM) will move from reporting requirements to financial obligations in January 2026. EU importers of goods like cement, steel, aluminium, fertilisers, electricity and hydrogen must purchase CBAM certificates based on imported goods’ embedded emissions – with credits for carbon costs already paid in the country of origin.
The Norwegian government has proposed an Act on a Carbon Border Adjustment Mechanism for imports into the EEA (the “CBAM Act”) to apply carbon pricing. The Bill implements Regulation (EU) 2023/956 (the “CBAM Regulation”) in Norwegian law, establishes powers to administer the regulation via secondary legislation, and provides for transposition of expected delegated and implementing Acts once they are incorporated into the EEA Agreement following consultations between EEA/EFTA states and the European Commission. Implementing CBAM will also require changes to Norwegian customs legislation.
The Bill was published for consultation in October 2025, with a consultation deadline of 2 January 2026. The Norwegian government aims to implement the CBAM regime from 2027. Rules on applying for and granting authorised CBAM declarant status are planned to come into force earlier so entities can obtain authorisation prior to 2027.
More broadly, CBAM signals a wider trend in international trade: emissions and carbon pricing are rapidly becoming as integral to competitiveness as traditional quality and cost metrics. Businesses that start early with product-level carbon reporting, supply-chain traceability, and contractual emissions clauses will be ahead of the compliance curve and in a position to access premium markets.
Maritime Decarbonisation
Maritime transport is at the forefront of the regulatory shift towards decarbonisation. FuelEU Maritime legislation, entering its second year in 2026, will require large cargo and passenger ships calling at EU ports to cut greenhouse gas intensity by at least 2% versus a 2020 baseline. These obligations do not just affect vessels moving between European destinations; they extend to half the fuel used on voyages that start or finish outside Europe, influencing any trade that touches EU ports.
The implication for operators is clear: costs for cleaner fuels, advanced monitoring equipment, and emissions verification will rise, and financial penalties for non-compliance will be strict. This, in turn, will drive a market premium for ports with reliable, certified supplies of low-carbon fuels, as well as for vessels capable of leveraging mechanisms like pooled compliance across fleets. Charter contracts are evolving to include emissions stipulations and fuel surcharges. Older, less-efficient ships may be redirected away from European trade or forced to absorb significantly higher operational costs.
This shift is also indirectly shaping investment in port infrastructure and alternative fuel supply chains across Europe. Norway, with its extensive coastline and advanced maritime sector, could seize new opportunities by developing green shipping corridors and accelerating investment in port electrification – a move that would solidify its competitiveness in Northern European trade.
The legislation is yet to be implemented by Norwegian authorities, but the Norwegian Maritime Authority has signalled that the implementation process is under way.
Rare-Earth Minerals and the Energy‑Transition Supply Chain
Rare-earth minerals have risen from a niche concern to a central pillar of European industrial and trade policy, especially as China tightens controls on certain rare-earth minerals and technologies. Norway possesses significant proven onshore and offshore reserves of rare-earth minerals and is already home to leading expertise in hydropower, port logistics, and metallurgical processing – all essential for the electric vehicle, battery, and wind-energy value chains that will dominate global industry going forward.
As the EU implements its Critical Raw Materials Act and comprehensive Battery Regulation (including requirements for battery passports, responsible sourcing, and recycled content), Norway is aligning its regulatory framework through the EEA. Adherence will increase compliance costs, necessitate investment in reporting and due diligence, and require close collaboration between industry, government, and supply-chain partners. Yet clear benefits are in reach: strategic project status, accelerated permitting, public financing, and preferred access to European contracts.
On the other hand, the US Inflation Reduction Act (IRA) presents a distinct challenge. Without a US–Norway critical minerals agreement, Norwegian-processed materials do not qualify for key US tax credits awarded for locally sourced minerals. As a result, Norwegian producers may prioritise European off-takers or enter into joint ventures with qualifying US-based firms.
Digitalisation and Customs Technology
Digital transformation is changing the landscape of international trade. Norway is investing strongly in customs digitalisation, not only to comply with EU requirements like Import Control System 2 but also to enhance the efficiency and traceability of its own trade flows via the mandatory adoption of the Digitoll platform in 2026.
The benefits of advanced customs technologies are multi-layered. They reduce processing times, limit errors, and allow for quicker identification of compliance risks or potential circumvention attempts. Automation of import-export filings, digital certificates of origin, and document authentication also enable smaller Norwegian exporters to compete more effectively, lowering barriers and fostering inclusion in global value chains.
Participating in new data-sharing initiatives and standardised electronic documentation will be essential for Norwegian logistics companies and manufacturers, linking them more closely to the global supply chain ecosystem. Digital readiness will soon be as important as logistics capacity or price competitiveness in securing lucrative international contracts.
Outlook and Takeaways
In 2026, Norway’s strategic task is to remain an open, reliable supplier to Europe and its allies, while navigating growing compliance burdens and heightened geopolitical risk. Companies that focus on origin planning, ESG data, and dual-regime compliance will be best positioned to access premium markets and ensure stable demand amid evolving trade realities.