Federation of Norwegian Industries (Norsk Industri)
The Federation represents around 3000 member companies with approximately 127,500 employees.
ID: 201845053314-57
Lobbying Activity
Response to Advanced Materials Act
17 Dec 2025
The Federation of Norwegian Industries support the development of a European Advanced Material Act. We agree that there is a need to align priorities for advanced materials in the EEA states, strengthen innovation and production of advanced materials and simplify policies and laws to boost investments in Europe. The new Advances Materials Act should boost R&I capacities and increase the cooperation between EEA states on setting up technology infrastructure. This includes facilitating financing and funding programmes, development of investment prioritization mechanisms for technology infrastructures in Europa and improvement of access to such R&I capacities. The Norwegian Government set up five industrial R&I centers around Norway (so called "Norwegian catapult centers"). These centers offer industry access to equipment, technology, and expertise. By setting up technology infrastructure, both small and large companies in different industry branches may develop, test, and simulate their processes and products to build competitiveness. The goal is to achieve more innovation, faster restructuring, and stronger competitiveness in the Norwegian industry. One of the industrial R&I centers in Norway specialize in advanced materials. The centers are linked to eight other industrial cooperation clusters, which benefit from the technology infrastructure at the R&I centers. We believe that the new advanced material act should encourage cooperation between R&I centers in Europe and secure funding programmes for setting up such technology infrastructure. Furthermore, the new act on advanced materials should make sure public investments can be used to support advanced manufacturing technologies, further expand efforts to strengthen skills and training in Europe, consolidate Europes leadership in global standards, promote digital product standardization, while at the same time protect intellectual property rights and trade secrets. For any other input, we express our support to the previous recommendations from the EU Industrial Forum Orgalim, with regard to strengthening advanced materials manufacturing, see https://www.eitmanufacturing.eu/news-events/news/advanced-manufacturing-at-the-heart-of-a-resilient-sustainable-and-competitive-europe/ and https://orgalim.eu/resource/advanced-manufacturing-seizing-europes-opportunity-to-lead-the-global-manufacturing-transformation/.
Read full responseResponse to Carbon border adjustment mechanism (CBAM) methodology for the definitive period
19 Sept 2025
The Federation of Norwegian Industries supports the introduction of CBAM in the EU and Norway. It is in the interest of both Norway and the EU that CBAM functions as intended, providing companies competing globally with effective protection against carbon leakage and contributing to increased profitability for production with a low carbon footprint. Although introducing a carbon border adjustment mechanism is a step in the right direction, the current design of CBAM has weaknesses that could both erode the climate effect of the regulations and threaten the competitiveness of European industry. These weaknesses must be addressed in order for CBAM to become an effective protection against carbon leakage. Indirect emissions should be based on a location-based method: CBAM products from industries that do not currently have compensation for indirect CO2 costs will be subject to CBAM on indirect emissions, and the methodology for this is imminent. In general, the methodology should be based on calculating indirect emissions based on the average CO2 intensity of the power mix of the country where the product is produced, based on globally recognized data for the electricity mix. Such a methodology can incentivize third countries to decarbonize their power sector, while ensuring uniform and accurate data. If it is permitted to use power purchase agreements (PPAs) to calculate indirect emissions, as the CBAM methodology now assumes, producers in third countries will be able to document no indirect emissions even from countries with power mixes where the reality is a high carbon footprint. CBAM on indirect emissions should not replace indirect carbon cost compensation: Regardless of the methodology, CBAM on indirect emissions should not replace the current scheme with indirect carbon cost compensation. For sectors not covered by indirect carbon cost compensation, other measures to handle indirect emissions should be introduced. In the Norwegian and European power markets, power prices are affected by the price of CO2 allowances, and European power consumers therefore have indirect CO2 costs in their power consumption. At the same time, competitors from countries outside the EU have no or very low such costs, because power markets outside the EU are little affected by CO2 prices. If indirect emissions are included in CBAM, European and Norwegian production will have significantly higher CO2 costs because of the CO2 price effect in the power price than producers outside Europe. The CO2 price effect on the power price could remain significant also through the 2030s, even with an increased share of renewables. Indirect carbon cost compensation should therefore not be replaced by CBAM on indirect emissions until the EU's power mix is decarbonised. Default values: Default values will play a decisive role in ensuring that CBAM delivers both climate integrity and competitiveness. They are the foundation of the system when actual emissions data is unavailable and must be designed to mirror the EU ETS, prevent circumvention, and provide clarity for regulators and industry alike.
Read full responseResponse to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines
3 Sept 2025
The European manufacturing sector are already in decline under the pressure of an increasingly uncompetitive cost structure, driven in large part by the regulatory framework and, most critically, by the escalating price of energy. For electro-intensive industries operating in highly competitive global markets, maintaining compensation for the indirect CO costs embedded in electricity prices is absolutely essential. Without such measures, Europes industrial base will be further disadvantaged, exacerbating an already uneven playing field and accelerating the erosion of Europes competitiveness, jobs, and strategic autonomy. European power-intensive industries competitiveness in global markets remains heavily dependent on retaining compensation for incurred indirect costs in power prices in order to maintain a level playing field. We expect this review to revise the current CO2 emission factors to reflect the development in the electricity markets. Although there is more renewable energy in the power mix across Europe, power prices are still heavily influenced by fossil fuel power plants as these technologies are often the marginal price setter. In Norway close to all electricity generation is renewable, but still the price is set by coal- or gas fired power plants in neighbouring markets. The applied CO2 emission factor (the influence of CO2 costs on power prices) should be as accurate as possible. To achieve this, we strongly recommend to continue allowing for a factor based on marginal price-setting principles, derived from the use of power market models with an accurate representation of all European markets. In Norway additional sectors are deemed eligible for state aid under the guidelines for ETS, e.g. NACE 20.14 (other organic chemicals) and 20.15 (fertilizers). Norwegian authorities have supplied detailed information to the EFTA Surveillance Agency to substantiate the need to include these sectors. We suggest that this revision includes these sectors from 2026 onwards. For sectors PRODCOM 20.13.21.70 and 24.10.12.35/36 the definitions in Annex II of the SAG of what is included in the benchmark are unclear. The definitions applied for these sectors in Annex II of the SAG for the period 2013-2020 were clear and should therefore be applied for the period 2026-2030. There are benchmarks in place for electricity consumption efficiency. Applicable electricity efficiency benchmarks, due to be revised, should remain based on actual consumption data provided by industrial sectors. A good and transparent process involving industry, should be preferred if benchmarks are to be updated. CBAM on indirect emissions should not replace the current scheme with CO2 compensation. The CO2 price effect on the power price will likely remain significant also through the 2030s, even with an increased share of renewables. CO2 compensation should therefore not be replaced by CBAM on indirect emissions until the EU's power mix is decarbonised. CBAM will not be able to accurately quantify the price-effect of the indirect emissions of imported goods. This is due to the fact that the level of indirect emissions in imported goods is often unclear, indirect emissions do not have price in 3rd countries, and the fact that in EU/EEA even products with no indirect emissions have a significant indirect emission cost.
Read full response26 Aug 2025
The Federation of Norwegian Industries supports the introduction of CBAM in the EU and Norway. The following feedback relates to the possible expansion of the scope of CBAM: Materials that compete with current CBAM products should be included in CBAM: Expanding scope of CBAM to other products can be considered when the existing CBAM framework has been improved and is documented to provide solid carbon leakage protection, a robust and comprehensive solution for CBAM sectors exports and to truly establish a real level playing field. Aluminium competes with other materials in a number of markets. For example, both aluminium and copper can be used in heat exchangers and electrical wiring. However, copper is not included in CBAM. Because CBAM results in a higher price for aluminium, but not for copper, the relative competitiveness of aluminium will be weakened. Other materials that should be considered for expansion include nickel and cobolt. When expanding to new materials, important downstream products should be correspondingly included to avoid carbon leakage. For nickel and cobolt, this would be a.o. batteries and special steel. Ammonia is a low-emission fuel for shipping, but other low-emission fuels that compete with ammonia are not included in CBAM. This applies in particular to methanol. Methanol and other hydrogen derivatives should therefore be included in CBAM to ensure the most level playing field for imported low-emission fuels. Including scrap-based aluminium imports in CBAM: Current regulations allow for scrap remelted into aluminium products to be imported without paying CBAM. Scrap originating from aluminium with a high CO2 footprint can thus be imported into Europe without a CBAM cost. This allows imported scrap with a high carbon footprint to outcompete European metal with a low carbon footprint and could have very negative effects on aluminium recycling in the EU. The most effective solution is to include all scrap-based aluminium imports in CBAM and assign a default value equivalent to primary aluminium to the scrap content ("precursor"). Include more product categories: As the regulations currently stand, many downstream metal products can be imported without being covered by CBAM. This provides incentives to move further processing out of Europe and then sell finished products back, without CBAM costs. For CBAM to work, more product categories must be included in the scheme. Within aluminium specifically, the inclusion of automotive products should be prioritised. Products with a high aluminium value in relation to the final price and which are highly commercial (less degree of value added/degree of differentiation) should also be included. For example, aluminium products within the following categories should be included: Cars (e.g. wheels, body panels); Packaging (e.g. cans, food packaging); Electrical (e.g. cables); Construction (e.g. window frames, architectural solutions) See attached file regarding CBAM CN CODES scope extension.
Read full responseResponse to Circular Economy Act
20 Aug 2025
Please find attached the contribution from the Federation of Norwegian Industries.
Read full responseResponse to European grid package
9 Jul 2025
The Federation of Norwegian Industries welcome the opportunity to provide input on the forthcoming Grids Package. Reliable and affordable infrastructures are crucial for the industry and its transition to carbon neutrality. EII are crucial role facilitating the stability, flexibility and decarbonisation of the European energy system. This requires secure and competitive power and grid access. Industrial actors are central to enabling demand-side flexibility, provide opportunities for scaling the capture of CO2. The success of this transformation depends heavily on interconnected and future-proof European grids that are planned, built, and operated to reflect the needs and capabilities of all key actors including industrial consumers. The rapidly growing capacity needs, with considerable associated costs for grid users, as well as the changes in the nature of the energy value chain require a reorientation of how we plan, operate and govern our energy infrastructures. It should always be a priority to utilize existing grid first and it will not be in conflict with building new grid if necessary. In our experience, there is ample capacity in the grid except for certain short periods when the grid is utilized close to its limits. Such periods can for instance be a cold winter day or a warm summer day. Outside these periods, the grid has plenty of capacity, which could be utilized much better than today. Interconnectors should be based on open and transparent socioeconomic analysis sufficiently taking into account the features of the power system in each country/region and how it is set up, including assessments of the impact on security of power supply within regions/states. It should furthermore include an impact assessment on consumers and in particular the competitiveness on the European industry exposed to international competition. It should be upon the decision of the Government/the Member state whether an investment should be accomplished or not. The future development of interconnectors must be coordinated between the Member states and included in the offshore wind development plans. Grid connection lead times vary across Member States and are driven by a number of factors, namely, scarcity of capacity, ghost projects or speculative requests over-reserving capacity, and lengthy permitting processes. The solutions for active management of these connection queues should be determined on national level. We recommend Member States consult with their system operators on whether they are able to efficiently manage their connection requests with the existing, default first-come, first served principle. If system operators indicate that this principle is preventing them from effectively managing all of their connection requests in a timely fashion, Member State governments and regulators should then take the political decision on how to prioritise grid users based on relevant national objectives. Furthermore, we encourage grid companies to be more transparent about their grid and in their assessments of available capacity. The EU should evaluate if it would be desirable and possible to seek necessary permits for grid projects before the need has materialized but invest and construct only when the need is there. This should carefully be considered against the benefits of securing premature permits and the workload required and the risk of seeking permits for grid solutions that not necessarily are fit for purpose when the need for grid capacity materialize. In addition to the financing of grid projects, the EU should also address the increasing grid costs for the consumers through rising grid tariffs. These must be affordable to the European industry and for its citizens. We see a risk that grid tariffs will increase significantly if all the plans are executed, the cost for high voltage equipment is maintained at a high level and grid companies arguing for higher profits (WAAC). To some extent we already see the effect.
Read full responseResponse to Oil and gas producers' contributions to the 2030 Union CO2 storage objective
8 Apr 2025
The Federation of Norwegian Industries, representing more than 3 200 industrial companies and more than 145 000 employees in Norway, welcome this opportunity to provide feedback on the delegated regulation on carbon storage under the Net Zero Industry Act (NZIA). Carbon capture and storage (CCS) as well as industrial carbon removal based on CCS technologies, are essential for meeting our shared emission reduction objectives. Our Federation supports the Commissions work on creating a comprehensive EU strategy for carbon capture, transport, usage, and storage, as well as the ambition to create a single market for CO2 transport and storage services by 2030. The establishment of carbon storage facilities under the Net Zero Industry Act (NZIA) is a key step towards this objective. Indeed, the development of carbon storage facilities is becoming an urgent matter. Norway is a global frontrunner having safely stored CO2 since 1996 at the offshore Sleipner gas field, and later at the Snøhvit LNG-facility in northern Norway. Hence, we are at the forefront when it comes to research, capture technologies, project planning and execution, transport and storage. Norway has ambitious industry actors eager to contribute towards the net zero economy both at home and abroad. The state-supported Norwegian Longship project has in many ways solved the "chicken and egg"-problem for the first European capture projects within the cement industry (Heidelberg Materials) and waste-to-energy (Hafslund Oslo Celsio), by securing storage for these first movers. Northern Lights, the transport and storage part of the Longship project, offer permanent CO2 storage to European customers with an annual storage capacity of up to 1.5 million tons CO2 in the first phase of the project, expected in operation by the second half of 2024. Recently, a final investment decision was taken for phase 2 which is scheduled for operation in 2028 and increase the annual storage capacity to more than. However, the opportunities on the Norwegian Continental Shelf (NCS) are much larger, and several exploration and storage licenses have already been awarded by the Norwegian Ministry of Energy. We welcome the European CO2 storage target proposed in the NZIA. To reach the target, it is essential that the capacity obligations can be met through storage facilities on the Norwegian continental shelf. Our experience is that public acceptance of offshore CO2 storage is significantly higher than of onshore storage. In Norway, the industry has plans to develop further CO2 storage projects offshore, leading to a rapid escalation of the annual overall storage to potentially 40-50 million tons in 2030. By connecting large emission sources in Europe with the extensive storage opportunities on the Norwegian continental shelf, Norway can play a key role in achieving Europes climate and green industrial objectives, including the NZIA. Some onshore industries have significant CO2 emissions and are located close to the sea. However, there are also CO2-emitters with 100 000 tonnes CO2/year or less that are relevant for CCS. Such companies have in many cases done feasibility and concept studies for CO2-capture but do lack a commitment that their CO2-emissions will be suitable for transport and storage. It seems as if it is only the larger emission sources that are of interest. Investment decisions for CO2-capture will only come when infrastructure is available and the cost for transport and storage is known.
Read full responseMeeting with Jan Hendrik Dopheide (Cabinet of Commissioner Maroš Šefčovič)
6 Mar 2025 · Introductory meeting / EU-NO relations