This report has been commissioned by the Nordic Environment and Economy programme (NME). The report has been prepared by a consortium led by Norion Consult in cooperation with IVL and ETLA.
EU’s carbon border adjustment mechanism, CBAM, aims to prevent carbon leakage and stimulate more ambitious climate policies globally by imposing a carbon levy on imports of certain product groups from countries outside the EU. The price of carbon is linked to EU ETS thereby securing that the price of carbon is the same regardless of where in the world the manufacturing of the commodity. CBAM was fully implemented by January 2026 and initially it applies to the product groups cement, iron, steel, aluminium, and fertilizer.
The overall purpose of this project has been to analyse the current implementation of CBAM in the Nordic countries and how a potential extension of the current framework affects Nordic countries. The report focuses especially on the implementation of CBAM in the EU Member Countries Sweden, Denmark and Finland. The report concludes that the Nordic countries might benefit from an expansion of the framework to include indirect emissions as that would allow Nordic producers to benefit from the cleaner energy mix. The Nordic countries are recommended to prepare strategically for inclusion of indirect emissions, consolidate and streamline national implementation, and use CBAM as a lever for green industrial transition. Although CBAM is effective, there are many uncertainties as to how the long-term framework will look like. CBAM is only one of many elements in an effective climate and industry policy mix. Effective CBAM implementation in the Nordics must be paired with overall policy stability, technological support and stakeholder dialogue.
Members of the Nordic Environment and Economy programme have provided comments and inputs to the report during the work. The authors of the report are responsible for the content as well as the assessments and recommendations, which do not necessarily reflect the views and the positions of the governments in the Nordic countries.
January 2026
Lisa Björk
Chair of the Nordic Environment and Economy Programme