Electricity imports into the European Union are taking shape as a carbon-compliance market under the Carbon Border Adjustment Mechanism (CBAM), which assigns a financial consequence to emissions linked to imported power. The approach can affect how generators and traders position supplies, depending on whether they can document qualifying physical electricity and substantiate associated emissions.
The European Commission’s transitional registry recorded about 96 million MWh of electricity imports between the fourth quarter of 2023 and the second quarter of 2025. The United Kingdom accounted for roughly 65% of the reported volume, followed by Serbia at 15% and North Macedonia at 5.2%. Bosnia and Herzegovina and Montenegro were also listed among principal origin countries.
These figures reflect historical declaration shares during the transitional period rather than audited market shares for 2026. They are based on reporting within the CBAM electricity transitional arrangements, not on a later verified breakdown of import volumes for the next compliance year.
Default emissions factors dominate transitional declarations
During the analysed transitional period, around 97% of electricity declarations relied on default emissions factors instead of data tied to actual electricity generation. The Commission estimated that the reported imports corresponded to approximately 86 million tonnes of CO₂ equivalent. It also cautioned that defaults based on fossil-fuel generation may overstate embedded emissions for some electricity flows.
The Commission’s estimate is therefore not presented as a measurement of emissions for every imported megawatt-hour. Instead, it indicates how the emissions calculation can change when generation-specific evidence is unavailable or does not meet applicable requirements.
Under the definitive CBAM framework, establishing the correct emissions treatment can influence the carbon cost applied to imported electricity. For the third quarter of 2026, the reference price reached €82.32 per tonne of CO₂ equivalent. The carbon charge may vary depending on whether an authorised declarant applies default values or substantiates actual emissions from a qualifying generating installation.
Requirements for using actual emissions values
The legal conditions for using actual emissions values are specific. The framework requires a qualifying power purchase agreement between an authorised EU declarant and a third-country electricity producer, or a permitted intermediary arrangement.
Evidence must also cover physical connectivity or confirm the absence of network congestion at export time, assessed hourly, alongside other statutory and implementing requirements. Metering records, transmission schedules, contractual allocation and a defensible link between the generating installation and the imported electricity can therefore become commercially significant.
A guarantee of origin or a general claim that a trader purchased renewable electricity is not sufficient on its own. While such instruments may support broader energy-accounting processes, they do not replace the CBAM-specific conditions needed to use actual emissions values for imported electricity.
Low emissions at a generating plant do not automatically establish eligibility where electricity moves through a trading chain that cannot be adequately traced. The ability to demonstrate the required connection between generation, contractual arrangements and physical delivery is central to any claimed carbon treatment.
Commission proposals on attribution do not change 2026 obligations
The European Commission has proposed changes to electricity-emissions attribution as part of its wider downstream CBAM package. The proposals aim, among other elements, to improve how decarbonisation outside the EU is treated. The reform remains subject to legislative negotiations and is not treated as an existing right.
Importers preparing their 2026 CBAM declarations must apply the rules currently in force. Anticipated future flexibility cannot justify an emissions calculation unless the relevant changes have been adopted and become applicable.
For Western Balkan generators, this framework can translate into a commercial opportunity to offer a more complete supply product combining electricity delivery, an appropriate contractual structure and verifiable evidence linking the generating installation to the EU border. The distinction may be particularly relevant for wind, solar and hydropower producers, as well as developers exploring storage-linked supply strategies.
Banks assessing such projects are expected to distinguish between a megawatt-hour that can be physically traded across borders and one that meets legal conditions for an actual-emissions claim under CBAM. Competitive advantage is not automatic for renewable electricity or low-emissions generation in isolation; it depends on whether exporters and authorised EU declarants can demonstrate the precise conditions required to support the claimed carbon treatment.