The European Commission has clarified that customs declarations for electricity imported into the European Union through explicitly allocated transmission capacity are tied to nominated quantities. The guidance makes reconciliation of cross-border schedules and customs records more important for Serbian exporters and traders supplying EU buyers.
Published on 6 November, the operational guidance covers imports under Centralised Clearance for Import, a customs procedure that allows import declarations to be handled through a centralised arrangement. It is not a new Carbon Border Adjustment Mechanism (CBAM) law and does not change wholesale price formation.
Schedules and commercial contracts
Serbia’s direct trading relationship with Hungary makes the guidance particularly relevant to the regional power trade. Serbian generators and suppliers can agree delivery volumes in power purchase agreements, while traders or intermediaries arrange transmission capacity and submit cross-border schedules.
Under the Commission’s explanation, declarations for electricity moving through explicitly allocated capacity are linked to nominated quantities, taking relevant hourly imports and exports into account. Traders need to reconcile commercial positions with accepted transmission schedules and the amounts declared for EU customs purposes.
A contractual sale, an exchange trade and a cross-border nomination can each describe a different part of the same transaction. A Serbian supplier may sell output to a trader, which can combine electricity from several generators before scheduling an export; the producer is not necessarily responsible for the EU import declaration.
Without a clear allocation record, parties may have difficulty establishing what quantity was imported, who imported it and under which contract. The guidance clarifies how the amount entering the EU is identified and supported in customs records.
CBAM exposure and evidence
CBAM increases the financial consequences of weak records. Serbia’s electricity default factor is 1.041 tonnes of CO2 per megawatt-hour, while the CBAM certificate price for the third quarter of 2026 was €82.32 per tonne.
Applying those figures gives an indicative unadjusted carbon amount of €85.70/MWh when the default factor is used. This is not a universal export charge: an importer’s actual liability depends on applicable rules and adjustments.
The customs guidance does not revise Serbia’s electricity default factor or change the conditions under which an importer may use verified actual emissions. For generators, the immediate risk is a break in the evidence chain between electricity sold and electricity imported, rather than a new regulatory cost.
Serbian traders should check that contracts identify who is responsible for cross-border nominations, customs formalities and CBAM declarations. If separate entities handle those tasks, agreements should give the importer access to schedules, invoices and transmission-system records so an EU buyer can establish the declared volume and assess a claim for plant-specific emissions.
The guidance leaves wholesale price formation unchanged, while making customs reconciliation a more visible part of the route to market, especially when several traders stand between a Serbian generating plant and an EU buyer.
