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 that affect electricity procurement and contracts across Southeast Europe.
Electricity became a covered imported good when the definitive CBAM regime took effect on 1 January 2026. Importers must address the applicable customs declaration, carbon-accounting methodology and certificate obligations, while electricity is excluded from the 50-tonne de minimis exemption available for certain other CBAM goods.
Declarations and certificate costs
Purchases of CBAM certificates for 2026 electricity imports begin in February 2027, before the annual declaration and surrender deadline. The interval between imports and certificate settlement means importers face regulatory obligations before completing the associated settlement, making the financing of future certificate purchases, carbon-related price adjustments and responsibility for emissions information relevant to contract terms.
The authorised CBAM declarant is generally the importer or an eligible indirect customs representative that assumes the applicable obligations, according to the Commission’s guidance. 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.
Electricity trading takes place through interconnected networks, where commercial transactions, scheduled deliveries and physical power flows do not necessarily correspond to a simple bilateral shipment. In the Western Balkans and neighbouring EU markets, electricity may be sold through multiple counterparties and cross-border trading arrangements, requiring importers to reconcile customs declarations with the relevant trades and deliveries.
Origin and emissions evidence
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 rule is particularly relevant to transactions involving Serbia and Montenegro and neighbouring EU markets.
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. This distinction applies within trading arrangements where scheduled deliveries, commercial transactions and physical flows may not describe a simple bilateral movement.
Importers seeking to use actual emissions instead of default values must meet prescribed eligibility requirements. Their claims must be supported by appropriate contractual evidence, production and metering records, transmission nominations and independent verification, with evidence covering the quantities and time periods being claimed.
A renewable electricity certificate or a contractual statement describing electricity as green is not sufficient on its own to demonstrate compliance with every condition for using actual emissions. Importers must ensure that emissions information matches the relevant electricity imports and that supporting records can withstand regulatory scrutiny, including where power has moved through multiple trading and transmission arrangements.
Contract allocation and market documentation
The legal CBAM declarant and the party carrying the carbon-related financial cost may differ under electricity contracts. An EU trader may be the declarant while the contract allocates the cost to a generator, intermediary or industrial customer.
Steelworks, aluminium manufacturers, cement producers and other electricity-intensive EU consumers buying imported power may encounter CBAM-related costs through procurement arrangements even when they are not the declarant. Contracts need to address financing future certificate purchases, carbon-related price adjustments and which party is responsible for obtaining emissions information.
EU importers need compliance systems that reconcile customs declarations with electricity scheduling data, generation information and contractual obligations. The expanding responsibilities give Western Balkan exporters a commercial incentive to provide EU counterparties with clear, reliable and independently verifiable electricity documentation.
In cross-border electricity trading, competitiveness increasingly depends on the price and origin of power, evidence of where it was generated and clarity over which entity carries the carbon obligation. As the first annual compliance deadline approaches in 2027, CBAM responsibilities are expected to become more important in electricity procurement, contract pricing and counterparty selection throughout Southeast Europe.
Regulation (EU) 2025/2083 and an OECD customs implementation analysis from October 2026 are cited as research references concerning CBAM implementation.