The European Commission has published guidance clarifying how electricity passing through EU interconnectors is declared under centralised customs clearance and how responsibility for the import is identified for carbon-border purposes.
The explanatory guidance, published by DG TAXUD on 6 November and based on technical work finalised on 12 October 2026, addresses differences in customs practices for electricity transported through fixed infrastructure. It does not amend the legal scope of the Carbon Border Adjustment Mechanism (CBAM), but provides practical instructions for declarations in a market where goods cannot be presented for physical customs inspection.
Customs treatment
Electricity traded through interconnectors is classified under CN 2716 00 00. Where transmission capacity has been allocated explicitly, the entity responsible for holding and nominating that capacity for import is relevant to identifying the customs declarant and the party bearing the associated CBAM responsibilities under the applicable rules.
The Commission also explains how nominated quantities entering and leaving the customs territory in the same hour are considered when determining the electricity actually released for free circulation. This distinction is important for borders where commercial nominations, physical flows and transit arrangements do not coincide.
Under the guidance, importers using centralised clearance must combine the appropriate authorisation for Entry in the Declarant’s Records with supplementary declarations. Because electricity cannot be physically presented at a customs office, supervision relies on contractual documents, metering records, transmission-system information, commercial invoices and post-release checks.
The relevant customs documentation must identify the authorised CBAM declarant. The CBAM account number, including the appropriate Y128 customs reference, forms part of the reconciliation between import records and the EU’s regulatory systems.
Counting imported electricity
For example, where 10 MWh enters EU territory but only 8 MWh is released for EU consumption and the remaining 2 MWh is demonstrably in transit, the import declaration concerns the 8 MWh released for free circulation, not the entire flow crossing the border.
The guidance also reiterates a key distinction between the route of trading and the origin of the imported electricity. Origin is associated with the country where the electricity was generated, rather than automatically changing when electricity is resold through an intermediary market outside the EU.
Implications for traders
The implications are significant for traders operating between Serbia, Montenegro, Bosnia and Herzegovina, North Macedonia and neighbouring EU electricity markets. Transactions involving separately nominated interconnector rights require clear assignment of responsibilities among generator, trader, capacity holder and EU importer.
For renewable-power projects negotiating physical power purchase agreements, documentation must connect generation information, metering, nominations, settlement and the importing entity. A guarantee of origin or a renewable claim by itself does not establish eligibility for actual-emissions treatment under electricity CBAM.
Documentation and obligations
Importers and traders should reconcile the hourly transmission schedule with the customs import quantity, retain evidence of genuine transit and verify that declarant authorisation and account identifiers are consistent across their records. Banks assessing export-backed power projects need to distinguish contract prices from revenues demonstrably supported by deliverable and adequately documented electricity.
The guidance narrows administrative uncertainty, but it does not create a renewable-electricity exemption or replace the separate statutory criteria governing actual emissions, independent verification and the certificate obligation.