EU customs statistics attribute 9.845 TWh of electricity imports to Serbia across four EU markets in 2025, with Hungary and Romania accounting for nearly 7 TWh combined. The reported gross imports are valued at approximately €1.15 billion. The figures reflect trade flows and border attribution, but do not identify which Serbian power plants generated the electricity for CBAM carbon accounting.
Hungary recorded 3.636 TWh of imports, worth approximately €427.8 million, while Romania reported 3.131 TWh, valued at approximately €381.8 million. Bulgaria recorded 1.625 TWh worth approximately €190.4 million, and Croatia reported 1.254 TWh valued at approximately €130.1 million. These totals are based on customs records for cross-border electricity movements.
Customs attribution differs from installation-level CBAM evidence
The reported totals represent gross trade flows rather than Serbia’s net domestic electricity exports or independently verified generation. Electricity can be scheduled across multiple borders and traded more than once, so a customs record attributing an import to Serbia does not establish that a specific Serbian generating unit supplied the megawatt-hours. Public cross-border statistics therefore do not provide installation-level sourcing for emissions treatment.
For CBAM purposes, the customs origin shown in trade statistics is not the same as a verified identification of the installation that generated the electricity. The CBAM framework covers electricity under CN 2716 00 00, while the cited trade data use HS271600. The exemption for consignments below 50 tonnes does not apply to electricity.
The EU importing declarant is responsible for accounting for embedded emissions from imported electricity. For imports into Hungary and Romania, this responsibility formally falls to the authorised EU declarant, which may be an electricity trader, supplier or another eligible importing entity. Industrial consumers may face higher prices indirectly through supply contracts, but they are not identified as the customs declarant.
Documentation requirements for actual emissions and metering links
The use of actual electricity emissions instead of prescribed default values is subject to strict regulatory conditions. A standard renewable electricity purchase agreement or a guarantee of origin alone does not demonstrate that all CBAM conditions have been met. Linking a reported import to a generating installation requires matched generation-meter records, dispatch schedules, evidence of the contractual chain and nomination records.
The information available in public cross-border statistics also does not identify the steelworks, chemical plant, factory or data centre that ultimately uses the electricity. That level of linkage would require supply and settlement data beyond customs attribution. As a result, customs totals alone do not determine how imported electricity emissions are treated under CBAM.
Serbia’s Ministry of Finance estimates for 2026 CBAM exposure
Serbia’s Ministry of Finance modeled electricity-related CBAM exposure of €21.8 million in 2026 under a baseline scenario. The ministry also noted that already-weaker trade flows could make the actual effect lower than this figure. Separate estimates were €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 ministry’s three figures are based on separate assumptions and are not described as cumulative costs or as a regulatory concession already in force. For traders, import economics depend on hourly market prices and congestion, with an additional carbon charge potentially increasing the minimum price difference needed to justify imports from a non-EU border during hours when EU renewable generation is abundant. A portfolio that appears profitable before CBAM and transmission charges may become marginal once exposure to default emissions is included.
A proposed practical remedy is an auditable evidence chain linking each imported volume and its EU declarant with the generating installation, metering, dispatch and cross-border schedule. For Serbian exporters and their EU buyers, documentation capability may therefore affect competitiveness alongside transmission capacity and wholesale prices. The available customs totals do not provide installation-level evidence needed to determine the actual emissions treatment of imported electricity.
Elevated by CBAM by Clarion Engineer