The European Commission published a proposal on 7 September 2026 aimed at supporting mutual recognition of Guarantees of Origin between EU member states and Energy Community contracting parties. The initiative would apply within a framework that is subject to agreement.
Renewable electricity producers in Serbia, Montenegro and other Energy Community markets could use the approach to access a broader market for the environmental attributes tied to their generation. The Commission proposal also links the initiative to potential changes in how renewable power purchase agreements are structured. Recognition of a certificate, however, would not by itself determine whether imported electricity qualifies for actual-emissions treatment under the Carbon Border Adjustment Mechanism (CBAM).
Council position sets conditions for recognising eligible Guarantees of Origin
The proposed Council position, COM(2026) 464, concerns an Energy Community Ministerial Council decision envisaged for 30 November 2026. Its objective is to establish conditions for recognising eligible renewable electricity certificates issued in Energy Community countries and the EU.
As of 17 October 2026, the process remained ongoing. The commercial effect would depend on adoption of the framework, compatibility between registries, domestic implementation, eligibility conditions and demand from European buyers.
For Serbian wind developers and Montenegrin hydropower producers, mutual recognition could make renewable attributes more accessible to EU customers seeking credible evidence for renewable electricity disclosure. Sales of those attributes could create an additional revenue stream alongside physical electricity sales.
Companies operating across multiple countries could also find it easier to procure and retire recognised certificates within their corporate sustainability programmes. The impact would still depend on how recognition is implemented and used by European buyers.
Certificate trading relies on issuance, ownership and retirement rules
Recognition would not guarantee a price premium for renewable certificates. Renewable generators are expected to identify who owns the Guarantees of Origin under each power purchase agreement.
The arrangements would need to specify whether certificates are bundled with physical electricity, which registry issues and transfers them, and which party is entitled to retire them. Contract terms also have to prevent the same renewable attributes from being promised or sold to multiple buyers.
Lenders assessing renewable projects should examine these ownership and transfer rights when evaluating projected certificate revenues. Such income may support project financing, but its value depends on secure ownership, reliable issuance and assumptions about market demand.
Guarantee of Origin recognition operates separately from CBAM eligibility
The proposed recognition framework would function separately from rules governing CBAM treatment of imported electricity. Eligibility for actual-emissions treatment under the electricity provisions requires a qualifying contractual and physical-delivery chain.
It also requires compliant generation evidence and independent verification. A Guarantee of Origin may support a renewable electricity claim in an appropriate context, but it does not establish that electricity was nominated across the border, that a relevant congestion condition was met, or that the EU importing declarant meets applicable requirements.
Treating certificate recognition as equivalent to CBAM qualification could therefore overstate the carbon-related value of an export project. Environmental attributes linked to renewable generation and the regulatory evidence needed for an eligible import must be assessed separately.
Sector-specific CBAM accounting affects industrial customers using recognised attributes
The distinction also applies to domestic industrial customers. A Serbian factory could purchase recognised renewable attributes for corporate electricity disclosure, but CBAM emissions on exported products would depend on sector-specific methodology.
Electricity consumption plays a different role in emissions accounting for covered cement and fertiliser products than it does under current CBAM treatment for covered iron, steel and aluminium goods. For those goods, only direct emissions are taken into account.
Manufacturers are therefore required to substantiate claims under rules applicable to each product category rather than assuming that buying renewable certificates automatically reduces CBAM obligations.
Power purchase agreements can separate electricity delivery from environmental attributes
A PPA structure could define physical electricity rights and renewable attributes in separate contractual schedules. It could also include provisions addressing CBAM-related evidence where relevant.
One schedule could cover electricity delivery, pricing, metering and balancing. A second could set out Guarantee of Origin issuance, ownership, transfer, retirement and invalidation.
A third schedule could address production, nomination and verification records needed to support a CBAM claim. This design would clarify what each payment covers and reduce the risk of double claims between renewable attribute purchases and acquisition of electricity meeting requirements for particular regulatory treatment.
For renewable developers across the Western Balkans, mutual recognition could widen the market for environmental attributes supporting corporate PPAs. The lasting commercial value would depend on maintaining certificate integrity while keeping renewable disclosure, physical electricity trading and CBAM verification legally distinct.
A recognised certificate may become easier to sell, but the imported megawatt-hour would still need to satisfy requirements tied to its own delivery route under CBAM rules.