EU electricity importers must account for embedded emissions and surrender Carbon Border Adjustment Mechanism (CBAM) certificates for power imported in 2026, with the first annual declaration and surrender due by 30 September 2027. The European Commission’s electricity-specific CBAM FAQ and information on the definitive regime and certificate calendar set out requirements affecting power procurement and contracts in Southeast Europe.
Electricity became a covered imported good when the definitive CBAM regime took effect on 1 January 2026. Importers must address customs declarations, carbon-accounting methodology and certificate obligations, and electricity is excluded from the general 50-tonne de minimis exemption available for certain other CBAM goods, the Commission’s information says.
That exclusion means importers cannot use the 50-tonne threshold to exempt smaller electricity transactions. Purchases of certificates for 2026 electricity imports start in February 2027, before the annual declaration and surrender deadline.
The interval between importing electricity and settling the associated certificates leaves importers with regulatory obligations before certificate settlement is completed. The Commission’s calendar and rules therefore make financing future certificate purchases, carbon-related price adjustments and responsibility for obtaining emissions information relevant to power contracts.
The authorised CBAM declarant is generally the importer or an eligible indirect customs representative that assumes the applicable obligations. In qualifying cases where electricity import capacity is explicitly allocated, the entity allocated and nominating that capacity and declaring the import to customs is treated as an authorised declarant without a separate authorisation application.
Origin and emissions evidence
Electricity trades through interconnected networks, where commercial transactions, scheduled deliveries and physical power flows do not necessarily amount to a simple bilateral shipment. The Commission’s guidance says that when electricity is produced in one non-EU country, traded through another and then enters the EU, its CBAM country of origin is the country of production, not automatically the intermediate trading country.
The origin and transit rules are particularly relevant to electricity transactions involving Serbia and Montenegro and neighbouring EU markets. Power in the Western Balkans and nearby markets can be sold through multiple counterparties and cross-border trading arrangements.
Electricity that enters and leaves the EU under an applicable customs transit procedure without being released for free circulation is not treated in the same way as electricity imported for EU consumption. The treatment depends on whether the power is imported for consumption or remains under the applicable transit procedure.
Importers seeking to use actual emissions rather than default values must meet prescribed eligibility requirements and support their claims with appropriate evidence. The Commission’s requirements include contractual evidence, production and metering records, transmission nominations and independent verification.
Documentation must support the quantities and time periods being claimed, and emissions information must match the relevant electricity imports. A renewable electricity certificate or a contractual statement describing power as green is not, by itself, sufficient to demonstrate compliance with every condition for using actual emissions.
Importers also need supporting records that can withstand regulatory scrutiny, including where power has passed through several trading and transmission arrangements. The rules require evidence linking the emissions information to the electricity imports being declared.
Contract costs and compliance systems
The legal declarant and the party carrying the carbon-related financial cost may differ under electricity contracts. An EU trader may be the CBAM declarant while a contract allocates the cost to a generator, intermediary or industrial customer.
Steelworks, aluminium manufacturers, cement producers and other electricity-intensive EU consumers that buy imported power may therefore encounter CBAM-related costs through their procurement arrangements even when they are not the declarant. Contract terms can determine who finances certificates and how carbon-related costs are allocated.
EU importers need compliance systems that reconcile customs declarations, electricity scheduling data, generation information and contractual obligations. Contracts also need to address financing future certificate purchases, carbon-related price adjustments and which party is responsible for obtaining emissions information.
These responsibilities create a commercial incentive for Western Balkan exporters to provide EU counterparties with clear, reliable and independently verifiable electricity documentation. The competitiveness of cross-border trading increasingly depends on the price and origin of power, evidence of where it was generated and clarity over which entity carries the carbon obligation.
EU industrial consumers may bear costs through contracts even where another party is the declarant, while importers must assemble evidence linking customs, scheduling and generation records. Regulation (EU) 2025/2083 and an OECD customs implementation analysis from October 2026 are cited as research references on CBAM implementation; the Commission’s calendar sets the first annual compliance date in 2027.
