Bosnia and Herzegovina could reduce the carbon cost attached to electricity exports to the European Union after several of its proposals were incorporated into draft revisions of the EU Carbon Border Adjustment Mechanism.
The Ministry of Foreign Trade and Economic Relations said the proposed changes had been forwarded to the European Parliament and the Council for consideration. They are intended to address the risk that electricity exporters from carbon-intensive but mixed-generation systems could be charged according to default values that fail to recognise renewable and lower-carbon production.
One proposed amendment would allow the carbon content of exported electricity to be calculated using the exporting country’s actual generation mix, including hydropower, wind and solar generation. Another would simplify verification requirements and recognise electricity supplied under power purchase agreements, including contracts arranged through intermediaries.
For Bosnia and Herzegovina, this distinction is financially material. The country remains dependent on coal-fired generation, but it also operates a substantial hydropower fleet. A methodology based only on conservative default factors can overstate the emissions attached to particular export transactions and weaken the commercial value of renewable electricity.
The proposals would also apply the revised treatment retrospectively from 1 January, potentially addressing costs incurred from the beginning of the definitive CBAM phase. The Ministry estimates that the combination of revised EU rules and a domestic methodology could reduce the annual burden on Bosnian electricity exports by as much as €13 million.
That saving will depend on evidence rather than on the national generation mix alone. Exporters will need metering records, dispatch data, contractual matching and verifiable information demonstrating the origin and emissions intensity of supplied electricity. Power purchase agreements will carry greater value only where the 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 the country’s electricity system. This is an essential step, but a national factor cannot replace plant-level and transaction-level monitoring where exporters seek preferential treatment for renewable or lower-carbon electricity.
The proposed changes could improve the position of Bosnia and Herzegovina’s hydropower producers and suppliers able to structure credible renewable export products. Coal-based electricity will remain exposed to carbon costs, particularly as EU importers strengthen due diligence around the accuracy of embedded-emissions declarations.
The legislative process is not yet complete. The draft must still pass through the European Parliament and the Council, and the final commercial benefit will depend on detailed implementing rules and the standard of verification evidence accepted by EU authorities.