Norway: Export Controls & Trade & Investment Sanctions

Norwegian capital managers and their portfolio companies face new challenges as the EU's forced labor regulation comes into force in December 2027, potentially blocking market access for products containing components from high-risk countries like China. With the U.S. using forced labor as justification for punitive tariffs and China implementing counter-sanctions that restrict supply chain investigations, companies must urgently reassess their procurement strategies and compliance frameworks.

On 18 December 2020, the Norwegian Government submitted a proposition for a new act on the implementation of international sanctions, see Proposition 69 L (2020-2021).