Proposed EU CBAM revisions for electricity exporters
Bosnia and Herzegovina could lower the carbon cost attached to electricity exports to the European Union after draft revisions to the EU Carbon Border Adjustment Mechanism incorporate several proposals. The Ministry of Foreign Trade and Economic Relations said the changes have been forwarded to the European Parliament and the Council for consideration. The aim is to reduce the risk that electricity exporters using carbon-intensive but mixed-generation systems are assessed using default values that do not reflect renewable and lower-carbon output.
One amendment would calculate the carbon content of exported electricity using the exporting country’s actual generation mix, including hydropower, wind and solar generation. Another proposal would simplify verification requirements and recognise electricity supplied under power purchase agreements, including contracts arranged through intermediaries.
Domestic generation mix and verification requirements
The Ministry said the distinction is financially material for Bosnia and Herzegovina. The country remains dependent on coal-fired generation, while also operating a substantial hydropower fleet. It said methodologies relying only on conservative default factors can overstate emissions linked to specific export transactions and reduce the commercial value of renewable electricity.
The proposals would apply revised treatment retrospectively from 1 January, potentially addressing costs incurred from the start of the definitive CBAM phase. The Ministry estimated that combining revised EU rules with a domestic methodology could reduce the annual burden on Bosnian electricity exports by as much as €13 million.
Evidence needed for preferential treatment
The Ministry said any potential savings depend on evidence rather than on the national generation mix alone. Exporters would need metering records, dispatch data, contractual matching and verifiable information showing the origin and emissions intensity of supplied electricity. Power purchase agreements would carry greater value only where contracted generation can be traced through scheduling, nomination, settlement and meter data.
The Ministry has prepared a methodology for calculating the carbon dioxide emission factor of Bosnia’s electricity system. It said this is an essential step, but a national factor cannot replace plant-level and transaction-level monitoring when exporters seek preferential treatment for renewable or lower-carbon electricity.
Legislative timeline and expected impact
The proposed changes could improve conditions for Bosnia’s hydropower producers and suppliers able to structure credible renewable export products. Coal-based electricity would remain exposed to carbon costs, particularly as EU importers strengthen due diligence around embedded-emissions declarations.
The legislative process is not complete. The draft must still pass through the European Parliament and the Council, and final commercial benefit will depend on detailed implementing rules and on what verification evidence EU authorities accept.
