EU importers of electricity must account for its embedded emissions and surrender Carbon Border Adjustment Mechanism (CBAM) certificates under the definitive regime introduced on 1 January 2026. The first annual declaration and certificate surrender for electricity imported in 2026 are due by 30 September 2027, with certificate purchases starting in February 2027.
The European Commission’s electricity-specific CBAM FAQ and information on the definitive regime set out the requirements. Electricity is a covered imported good and is excluded from the general 50-tonne exemption available for certain other CBAM goods, so importers cannot use that mass-based threshold to exclude smaller electricity transactions.
Regulation (EU) 2025/2083 and an OECD customs implementation analysis dated October 2026 are also cited as references for the rules. The interval between importing electricity in 2026 and completing certificate settlement in 2027 leaves importers with regulatory exposure before settlement.
Declaring imports and establishing origin
For covered electricity imports, EU importers must consider the customs declaration, carbon-accounting methodology and certificate obligations. The authorised CBAM declarant is generally the importer or an eligible indirect customs representative that assumes the applicable obligations.
Where electricity import capacity is explicitly allocated and the qualifying conditions are met, the entity allocated and nominating that capacity and declaring the import to customs is considered an authorised CBAM declarant without a separate application for authorisation. Commercial contracts, transmission arrangements and customs declarations therefore need to be coordinated to show how the import is handled and which entity assumes the obligations.
Electricity moves through interconnected networks, so commercial transactions, scheduled deliveries and physical power flows do not necessarily match a simple bilateral shipment. If 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.
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. These distinctions are relevant to transactions involving Serbia, Montenegro and neighbouring EU markets, where power may be sold through multiple counterparties and cross-border trading arrangements.
Importers seeking to use actual emissions instead of default values must meet prescribed eligibility requirements. They need to support their claims with appropriate contractual evidence, production and metering records, transmission nominations and independent verification, with records substantiating the quantities and time periods 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 CBAM emissions information matches the relevant electricity imports and that supporting records can withstand regulatory scrutiny.
Contract costs and emissions records
EU importers need compliance systems that reconcile customs declarations with electricity-scheduling data, generation information and contractual obligations. The requirements link the information used for carbon accounting to the specific electricity imported, its origin and the evidence available for the claimed emissions.
Electricity contracts need to address financing future certificate purchases, carbon-related price adjustments and responsibility for obtaining emissions information. The legal declarant may not be the party that bears the carbon-related financial cost: an EU trader may file as declarant while a generator, intermediary or industrial customer assumes the cost under contract.
Steelworks, aluminium manufacturers, cement producers and other electricity-intensive EU consumers buying imported power may therefore face CBAM-related costs through their procurement arrangements even when they are not the declarant. Western Balkan exporters have a commercial incentive to provide EU counterparties with clear, reliable and independently verifiable electricity documentation.
Competitive advantage in cross-border electricity trading is increasingly linked to documenting what was imported, where it was generated and which entity bears the resulting carbon obligation, as well as the price and origin of the power. As the first annual compliance deadline approaches, CBAM responsibilities are expected to become more important in electricity procurement, contract pricing and counterparty selection throughout Southeast Europe.