Insights / CBAM
Which Countries are Exempt from CBAM? Norway, Switzerland and Türkiye
Are goods from Norway, Switzerland or Türkiye exempt from CBAM?
Goods originating in Iceland, Liechtenstein, Norway and Switzerland are outside CBAM and do not count toward the 50 tonne threshold (Article 2(4) and Annex III of Regulation (EU) 2023/956). Türkiye is not in Annex III: the EU-Türkiye customs union gives no CBAM exemption.
What the act says
- Annex III point 1: Iceland, Liechtenstein, Norway and Switzerland, and the territories of Büsingen, Heligoland, Livigno, Ceuta and Melilla.
- Article 2(5): Origin means non-preferential origin under the Union Customs Code (Article 59 of Regulation (EU) No 952/2013), not the country you buy from.
- Article 60(2) UCC: Goods processed in more than one country originate where they underwent their last substantial, economically justified processing.
- Türkiye: Not in Annex III; steel and aluminium from Türkiye are CBAM goods like any other third-country origin.
What to do
- Check the origin on the customs declaration, not the seller's address: steel made in China and sold by a Swiss trader is not Swiss origin.
- Keep origin evidence for goods you treat as exempt.
Sources
- Regulation (EU) 2023/956 (CBAM), consolidated text (CELEX 32023R0956)
- Regulation (EU) No 952/2013 (Union Customs Code) (CELEX 32013R0952)
Last checked against the act text on 2026-10-20. For information only, not legal advice.