Hungary and Romania together reported nearly 7 TWh of electricity imports attributed to Serbia in 2025, within a total of 9.845 TWh across four EU markets. EU customs statistics valued the gross flows at approximately €1.15 billion, also reported as $1.30 billion, but the figures do not identify the Serbian generating installations relevant to the EU Carbon Border Adjustment Mechanism (CBAM).
Hungary reported 3.636 TWh, valued at approximately €427.8 million, and Romania recorded 3.131 TWh worth approximately €381.8 million. Bulgaria reported 1.625 TWh valued at approximately €190.4 million, while Croatia recorded 1.254 TWh worth approximately €130.1 million.
The totals measure gross reported trade flows and border attribution, not Serbia’s net domestic electricity exports or independently verified generation in Serbia. Electricity can be scheduled across several borders and traded repeatedly, so a border attribution does not show which generating unit produced a particular megawatt-hour.
Customs data do not establish CBAM emissions
For CBAM purposes, customs origin in trade statistics is not equivalent to a verified, installation-level identity for emissions. The mechanism covers electricity under CN 2716 00 00, while the cited trade figures use HS271600. The importer exemption for consignments below 50 tonnes does not apply to electricity.
The importing declarant must account for embedded emissions from imported electricity. For imports into Hungary and Romania, the formal obligation rests with the authorised EU declarant, which may be an electricity trader, supplier or another eligible importing entity. Industrial users may face higher prices indirectly through supply contracts, but that does not make them the customs declarant.
Using actual electricity emissions instead of prescribed defaults is subject to strict regulatory conditions. A standard renewable power purchase agreement or a guarantee of origin alone does not establish that the conditions for actual-emissions treatment have been met.
Linking an imported megawatt-hour to a specific Serbian generating installation requires matched generation-meter records, dispatch schedules, evidence of the contractual chain and nomination records. Identifying the steelworks, chemical plant, factory or data centre that ultimately consumes the power also requires supply and settlement data beyond publicly accessible cross-border statistics.
Ministry scenarios and trading economics
Serbia’s Ministry of Finance modeled electricity-related CBAM exposure at €21.8 million in 2026 under a baseline scenario, while warning that already-weaker trade flows could make the actual effect lower. It separately estimated €20.7 million under a scenario excluding transit effects and around €14.5 million if proposed rules on the national generation mix were adopted.
The three estimates reflect separate assumptions, not cumulative costs or a regulatory concession currently guaranteed to importers. The national-generation-mix rules are proposed. Electricity import economics also respond to hourly market prices and congestion; an additional carbon charge can widen the minimum price difference needed to justify imports from a non-EU border, particularly when EU renewable generation is abundant.
A trading portfolio that appears profitable before CBAM and transmission charges may become marginal when default-emissions exposure is applied. A proposed practical remedy is an auditable evidence chain linking each imported volume and its EU declarant to the generating installation, metering, dispatch and cross-border schedule. For Serbian exporters and their EU buyers, documentary capability may be as important to maintaining competitiveness as transmission capacity or wholesale electricity prices.
Elevated by CBAM.Clarion Engineer