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Confederation of Norwegian Enterprise

NHO

The Confederation of Norwegian Enterprise (NHO) is Norway's main employer and business federation, representing 30,000 private enterprises across manufacturing, services, and industry sectors.

Lobbying Activity

Response to Digital package – digital omnibus

13 Oct 2025

NHO welcomes the European Commissions efforts to streamline existing rules, reduce administrative burdens, and enhance legal clarity for companies operating across the EU. A more coherent and accessible digital regulatory environment is essential to foster innovation, competitiveness, and sustainable growth on the Single Market, which Norway is a part of through the EEA agreement. As a representative of the business community, we welcome the opportunity to contribute to the European Commissions consultation on the simplification of the digital regulatory framework. Please find our contribution in the attachement.
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Meeting with Maria Zafra Saura (Cabinet of Commissioner Michael McGrath) and Confederation of Finnish Industries EK and

2 Oct 2025 · Data protection and privacy

NHO urges extension and expansion of electricity cost compensation

5 Sept 2025
Topic — This consultation addresses state aid guidelines for industries facing carbon-related electricity costs.
Message — The organization demands that indirect cost compensation continues beyond 2030. They request the inclusion of chemical and fertilizer sectors in the guidelines by 2026. They also insist that Norway's specific calculation methodology must be maintained.123
Why — This would protect Norwegian industrial competitiveness by offsetting costs from fossil-based electricity.45
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Norwegian industry urges design fixes before extending CBAM scope

26 Aug 2025
Topic — EU consultation on extending carbon border taxes to downstream products and preventing circumvention.
Message — They demand design fixes before starting and an effectiveness assessment by 2028. They advocate for export compensation to protect producers in non-EU markets. They also request extending the scope to materials like copper to prevent substitution.123
Why — Export adjustments would protect Norwegian mineral fertiliser plants competing in non-EU markets.4
Impact — Importers of scrap-based products would face higher costs from new primary-metal carbon values.5
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NHO Warns Against Deindustrialisation and Urges Flexible ETS Pace

8 Jul 2025
Topic — The consultation reviews the EU emissions trading system and market stability reserve rules.
Message — NHO proposes phasing out allowances based on the industry's actual pace of change. They request that revenues be recycled into industry to support modernization and low-carbon solutions. The group also advocates for including carbon removal technologies in the trading system.123
Why — Industry would maintain competitiveness while receiving more financial support for their energy transition.45
Impact — Environmental goals could be compromised if allowance reductions are delayed to match industry.6
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Meeting with Jan Hendrik Dopheide (Cabinet of Commissioner Maroš Šefčovič)

8 Jul 2025 · Introductory meeting / EU-EEA and international trade

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

4 Jun 2025 · Simplification

Norwegian Industry Urges Inclusion of its Continental Shelf Storage

15 Apr 2025
Topic — EU regulation defining oil and gas producers' contributions to 2030 carbon storage targets.
Message — The organization insists that storage on the Norwegian Continental Shelf must count towards capacity obligations. They also recommend providing incentives for CO2 emitters to create market demand.12
Why — This would secure the business case for Norwegian projects and ensure their commercial viability.3
Impact — Storage providers lose if they are obligated to build capacity without guaranteed emitters.4
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Meeting with Nicolas Von Lingen (Head of Unit Secretariat-General)

6 Mar 2025 · State of play of implementation of the European Economic Area (EEA) Agreement

Meeting with Mario Nava (Director-General Employment, Social Affairs and Inclusion)

26 Feb 2025 · Courtesy visit to discuss social dialogue, cooperation with the EU

NHO urges EU to include all 30 EEA states in strategy

31 Jan 2025
Topic — This consultation aims to remove barriers and further develop the European Single Market.
Message — NHO requests a detailed plan to remove trade barriers and reduce regulatory burdens. They argue legislation must account for all 30 EEA states to protect value chains.12
Why — This ensures Norwegian firms operate on a level playing field within European value chains.3
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Meeting with Henning Ehrenstein (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Confederation of Finnish Industries EK and

14 Jan 2025 · Single Market Strategy

Meeting with Karin Karlsbro (Member of the European Parliament)

4 Dec 2024 · Handelsrelationer Norge och EU

Meeting with Niels Fuglsang (Member of the European Parliament) and Confederation of Finnish Industries EK and

13 Nov 2023 · 2040 Climate Target: Why The EU Must Maintain Climate Leadership

Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit) and industriAll European Trade Union and Norwegian Confederation of Trade Unions

13 Nov 2023 · The future of the social agenda of the EU

Response to European Critical Raw Materials Act

30 Jun 2023

The Confederation of Norwegian Enterprise feedback on Critical Raw Materials Act The Confederation of Norwegian Enterprise (NHO) is Norways largest organisation for employers, and the leading voice of business and industry in Norway. Norway and the EU enjoy a strong relationship, and the cornerstone of this relationship is the EEA agreement. Through this agreement, Norway is part of the EU Single Market, hence regulations determined at EU-level often applies to Norway. We would like to pay tribute to the European Commission for the work that has been put forward. NHO welcomes the Critical Raw Materials Act, and its sense of urgency in securing European access to raw materials. There is a need to lessen bureaucracy, long approval procedures, as well as a fasttrack scheme for future technologies. Speed and simple administration is essential, with information and documentation requirements at a minimum. We are in favour of "one stop shops". However, we are concerned about the ability to implement this in a harmonised way at national level. We would therefore urge the Commission to provide guidance on the implementation of the deadlines specified in Article 10 and Article 11. Please see our comments below: 1. Inclusion of EEA/EFTA states timelag Granted the proposal becomes EEA-relevant, as proposed by the Commission, there is a timelag from the proposal becomes implemented law in EU member states, to it becomes implemented law in the EEA/EFTA countries. To ensure the integrity of the Single Market, it is important to clarify the role of the EEA/EFTA countries in strategic projects / platforms from the start. We thus encourage the proposal to allow for flexibility. 2. The list of strategic raw materials needs a broader perspective The list of strategic raw materials in its current form is too narrow. Often, critical and/or strategic raw materials, are by-products in a value chain. Therefore, it becomes restrictive when bauxite but not aluminum is on the list. The Commissions impact assessment and strategic foresight report identify aluminum as fulfilling the definition of a strategic raw material, due to strong rising transition demand, an eroding EU production base, and the growing role of China and Russia in European supply. It is also important to note that aluminum will play an important role in the lowemission society and can be found as an activating component in almost all the technologies listed in the Net Zero Industry Act. Moreover, Phosphate rock and Phosphorus has a critical role in the European chemical and agricultural industries, also in batteries (as well as Silane and synthetic Graphite also missing on the critical raw materials list). 3. Involvement of the business community We would like to emphasise the importance of the business community being involved in the identification of strategic and critical raw materials, and the design of CRMA so that the initiatives are feasible when the law is implemented. 4. The proposal must better promote the development and distribution of secondary raw materials. Projects related to collection, sorting and recycling for replacement of raw materials must be given priority such as mining, processing and refining facilities. Recycling facilities have just as complex and lengthy permit procedures as projects for the extraction of primary raw materials. The free movement of waste within the EEA is equally important to ensure accessibility and sufficient volumes. In light of this, and taking into account that the EU currently does not have sufficient recycling infrastructure in place to recover the critical raw materials from its waste streams, it is important that the criteria for the recognition of strategic projects in Article 5 and Annex III are formulated in a way which safeguards this objective. The wording of Article 25 should require Member States to also take into account secondary raw materials in award criteria
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Norwegian industry group seeks early inclusion in net-zero act

22 Jun 2023
Topic — The Net-Zero Industry Act aims to boost green technology manufacturing in Europe.
Message — NHO asks to clarify the role of EEA countries in strategic projects immediately. They also request counting Norwegian carbon storage capacity towards EU targets.12
Why — This would allow Norwegian firms to access EU projects and monetize storage.34
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Norwegian industry urges voluntary approach to electricity market reform

23 May 2023
Topic — This consultation addresses reforms to make the EU electricity market more resilient.
Message — NHO supports the current market design while insisting that long-term contracting mechanisms remain voluntary for businesses. They argue that risk strategies should be commercial decisions and oppose using support systems for income redistribution.123
Why — This ensures Norwegian energy firms retain commercial autonomy and protects the existing efficiency of Nordic markets.45
Impact — Vulnerable consumers may miss out on price relief if redistribution measures like revenue caps are excluded.6
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Meeting with Valdis Dombrovskis (Executive Vice-President) and BUSINESSEUROPE and

16 Feb 2023 · Critical Raw Materials package

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

23 May 2022 · ETS

Meeting with Christel Schaldemose (Member of the European Parliament) and Confederation of Finnish Industries EK and

2 May 2022 · industri- og konkurrencepolitik

Meeting with Tomas Tobé (Member of the European Parliament) and Confederation of Swedish Enterprise

2 May 2022 · Labor market policy, European competitiveness, Nordic cooperation

Meeting with Mauri Pekkarinen (Member of the European Parliament) and Confederation of Finnish Industries EK and

2 May 2022 · Current EU industry affairs

Response to Revision of the Energy Tax Directive

18 Nov 2021

Please see attached file for NHOs response to the consultation on revision of the ETD.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

Please see attached file for NHOs consultation response to the proposed CBAM-regulation.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

NHO supports the EU's climate ambitions for 2030 and 2050 and we welcome the EU Fit for 55-package, which will be essential for achieving both climate goals and green growth. We appreciate the opportunity to comment on the revision of ETS. ETS is a core framework for ensuring both cost-efficient emission reductions, incentives for businesses and a transparent and harmonized climate policy across Europe. The importance of ETS and the implications for businesses will only increase going forward as the scope of ETS expands and the climate targets for 2030 increase. It is crucial that the ETS revision both give the right incentives for reducing emissions as well as ensuring risk mitigation for sectors in transition. Please see the attached file for our comments to the proposed revised directive.
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Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

5 Apr 2021

Confederation of Norwegian Enterprise (NHO) would like to thank the European Commission for the opportunity to comment on the roadmap. We strongly support the Commission´s objective on both the Green Deal and the Digital Strategy. Overall, the expansion of the General Block Exemption Regulation and the State aid modernisation has improved discretionary measures for the Member States, allowing them in some situations to take accurate account of the specific situation in their countries. However, improved discretion has also increased the risk of a more subjective and less uniform application of the State aid rules. The Commission has revealed important compliance gaps, especially regarding block-exempted measures that are directly implemented at national level. Hence, Member States need to improve their adherence to the rules and the Commission should continue to support their efforts. Aid for research, development and innovation The provisions on cluster policy under the GBER were introduced in 2014. The prevailing view was that the clusters were in the ownership of the research infrastructure in which the members could exploit in return for a remuneration. The clusters were envisaged to run the infrastructure with a purpose of serving the members. Against a market-based remuneration the clusters would deliver specialized services customized for the members. Hence, operating aid was for example limited in time because the clusters were supposed to being established as a service supplier for the members in which the members subsequently would account for the necessary financial means for the cluster organisation. From this angle, there is hardly any doubt that the clusters were considered an undertaking in terms of State aid rules and providing services in a market. However, today, the activities carried out by the clusters are often of a different nature. The activities pursue to a much larger degree an industry/research and regional policy agenda. This is further reinforced by the Green Deal and Digital Framework policies. The members only cover the costs to a certain degree. At the same time research organizations, companies etc. are carrying out both non-economic basic research and economic commissioned research. Very often, the same infrastructure, personnel and equipment are used for both activities. For this reason, several aid providers have a cautious approach in granting aid in order not to infringe any provisions in the GBER. In the view of NHO, more guidance is needed in order to manage this distinction and development of the cluster activities allowing for more targeted aid. A model of the RD&I Guidelines paragraph 18 could for example be further investigated. Regarding the incentive effect, in practice it is difficult to prove that aid for RDI influences a company to pursue research that it would not otherwise have pursued. The investment decision of an R&D project is based on multiple factors that can hardly be distinguished from each other. The subsidy alone often does not lead to a decision to invest, but reduces risks, speeds-up the process, stimulates collaboration with other companies etc. Fulfilling the requirement in the incentive effect can be extremely difficult and burdensome for companies, for example when multiple R&D project run simultaneously or the firm’s contribution to a single project is relatively small compared to the firm’s overall R&D budget. There should thus be less strict criteria on evidence related to the requirement that certain RDI activities are carried out in addition to normal day-to-day operations, also since competitors located outside the EU do not suffer from comparable constraints. GBER Article 2 paragraph 18, in particular litra a) and b) do not differentiate between start-ups whose intention is to spend capital on R&D or scaling and SMEs in real financial difficulties. An adjustment of the definition on undertakings in difficulties to this effect should be assessed.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

27 Jan 2021 · Speech at online yearly conference on the European single market organised in cooperation with The Confederation of Norwegian Enterprise (NHO)

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

NHO welcomes the opportunity to give our inputs to the delegated acts regarding climate mitigation and climate adaptation in the sustainable finance taxonomy. NHO believes that the taxonomy will only function as intended if it in practice contributes to drive forward the transition which is needed to reach the EU and Norway's ambitious climate goals towards 2030 and 2050. This requires that the taxonomy criteria are ambitious, while at the same time acknowledging the technological opportunities and boundaries of the economic activities included in the taxonomy. Furthermore, technological neutrality must be the guiding principle for the taxonomy; ensuring that all activities are treated equal and their contribution(s) to climate mitigation and adaptation are regarded without regard to political preferences For further comments on the technical criteria as proposed in the draft delegated acts, please see our comments enclosed.
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Response to Sustainable corporate governance

6 Oct 2020

The Confederation of Norwegian Enterprise (Næringslivets Hovedorganisasjon – NHO) is the main business organisation in Norway, with listed companies among our members. NHO is a member of Business Europe. We share the Commission's objectives in this field. However, we refer to the feedback given by the Confederation of Swedish Enterprise et al. We share there concerns regarding the Study on directors’ duties and sustainable corporate governance ("the Report"), as basis for the Commission's policy options. In essence, we support their feedback.
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Meeting with Nicolas Schmit (Commissioner) and

29 Jun 2020 · Meeting on minimum wage.

Response to A EU hydrogen strategy

8 Jun 2020

The Confederation of Norwegian Enterprise (NHO) welcomes the opportunity to comment and to provide inputs on the EU hydrogen strategy. NHO is Norway’s largest organisation for employers and the leading voice of business and industry in Norway. Our current membership of 28.000 companies ranges from small family-owned businesses to multinational companies in most sectors. NHO supports the EU ambition of net-zero greenhouse gas emissions (climate neutrality) by 2050 to reach the objectives of the Paris Agreement. Decarbonizing the EU economy in the next 30 years will require us to mobilize a number of solutions and technologies simultaneously. Increased renewable capacity is a prerequisite for reaching the EUs ambitions and direct electrification will be a solution for many sectors. However, there are a number of areas in which electrification will either be too costly, or simply not viable. The versatility of hydrogen makes it well fit to play a key role in a decarbonized European energy system. However, if it is to play this role it needs a both a market and secure supply of sufficient amounts of hydrogen to the market. It will also require developing an infrastructure that ensures that hydrogen is available where it is needed. To ensure this development, a EU Hydrogen strategy must promote the development of clean hydrogen value chains without discriminating based on technology. We believe both blue and green hydrogen have a role to play in a future European hydrogen market. In the short term, the political priority should be to ensure that we are able to produce sufficient amounts of clean hydrogen at a reasonable cost for consumers and to lay the foundation for a well functioning hydrogen market in Europe. Whether hydrogen comes from decarbonized natural gas, or excess renewable power should not be an issue, as long as we can be sure that the energy contributes to reducing emissions. However, "grey" imported hydrogen should face carbon cost for a level playing field as does petroleum and petroleum products. NHO have for many years promoted carbon capture and storage - CCS. In order to reach the climate ambitions, fossil fuels also need to becomemission free. Norway has the resources to contribute to building a European hydrogen market. We have significant reserves of natural gas, a large and flexible renewable power sector, and a competent process industry. This provides Norway with unique opportunities not only to produce blue hydrogen with CCS or green hydrogen by electrolysis, but also to manufacture materials, fuels, food or feed while recycling carbon. Fishfeed manufacturer Skretting is presently building a pilot using bacteria to transform captured CO2 and green hydrogen from Statkraft into protein feed. Full scale it will be a significant contribution to reducing carbon emissions from aquaculture, even making fish farming carbon negative Hydrogen and carbon management, starting with a logistic chain for handling CO2 is key, for value creation, for climate and nature protection (biodiversity). Several of our largest members with origin in the EU are involved in the Northern Lights project; French TOTAL, AngloDutch Shell, our own Equinor, Fortum of Finland and Norcem Heidelberg of Germany. An investment decision from the Norwegian government is expected soon. Demand side stimulation is also important. Norway have several hydrogen initiatives, green and blue, including ferries (Norled) and trucks (Asko), metallurgic processes from coal to hydrogen (TiZir), emission free hydrogen production from natural gas or emission negative from biogas (ZEG power and Reinertsen). We have the technologies and the uses but need to up-scale. Incentives for demand and production are necessary, such as support schemes for infrastructure investments, and binding targets of its use. Hydrogen must be made competitive towards alternatives at the supply side and renowned for its sustainability, usability, and flexibility at the demand side
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Meeting with Antonio Lowndes Marques De Araujo Vicente (Cabinet of Commissioner Carlos Moedas), Keith Sequeira (Cabinet of Commissioner Carlos Moedas)

25 Oct 2017 · Next Framework Programme

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

19 Sept 2017 · Discussion of the EU industry policy strategy and Norwegian industry's efforts to promote a clean and smart industry in Norway up to 2050.

Meeting with Jyrki Katainen (Vice-President)

19 Sept 2017 · Exchange on topical EU-issues

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

23 Mar 2017 · policy action relating to entrepreneurship

Meeting with Kilian Gross (Digital Economy)

19 Oct 2016 · digitising industry

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

28 Sept 2016 · industrial competitivenes, single market strategy, single market for goods

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

9 Jun 2016 · DSM

Meeting with Miguel Arias Cañete (Commissioner) and Equinor ASA and Offshore Norge

16 Feb 2016 · Package supply security and in particular the LNG strategy, EU-Norway relations in the field of energy

Meeting with Jyrki Katainen (Vice-President) and

14 Oct 2015 · Norway-EU economic relations and investment opportunities

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

14 Oct 2015 · DSM

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

14 Oct 2015 · New Trade Strategy & TTIP