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 requirements affect procurement, emissions evidence and contract terms for electricity traded across Southeast Europe. The European Commission’s electricity-specific CBAM FAQ and information on the definitive regime and certificate calendar set out the rules.
Electricity became a covered imported good when the definitive CBAM regime took effect on 1 January 2026. Importers must address customs declarations, the applicable carbon-accounting methodology and certificate obligations. Unlike certain other CBAM goods, electricity is excluded from the general 50-tonne de minimis exemption, so importers cannot use that threshold to exclude smaller electricity transactions.
Purchases of certificates for 2026 electricity imports begin in February 2027, ahead of the annual declaration and surrender deadline. That interval leaves importers with regulatory obligations before the associated certificate settlement is completed. Contracts therefore need to address financing future certificate purchases, carbon-related price adjustments and responsibility for obtaining emissions information.
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 in a qualifying case, the entity allocated and nominating that capacity, and declaring the import to customs, is treated as an authorised declarant without a separate authorisation application.
Origin and emissions evidence
Electricity trading takes place through interconnected networks, where commercial transactions, scheduled deliveries and physical power flows do not necessarily match a simple bilateral shipment. If power 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. These rules are particularly relevant to electricity transactions involving Serbia, Montenegro and neighbouring EU markets.
Power in the Western Balkans and neighbouring EU markets may pass through multiple counterparties and cross-border trading arrangements. 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. The transit route and the country where the electricity was generated therefore matter when importers establish how a transaction should be treated.
Importers seeking to use actual emissions instead of default values must meet prescribed eligibility requirements and support their claims with appropriate evidence. This may include contractual evidence, production and metering records, transmission nominations and independent verification. Records must support both the quantities and the 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 emissions information matches the relevant electricity imports and that supporting records can withstand regulatory scrutiny, including where power has moved through several trading and transmission arrangements.
Contract costs and compliance systems
The legal CBAM declarant and the party carrying the carbon-related financial cost may differ. An EU trader may be the declarant while a contract allocates the cost to a generator, intermediary or industrial customer. Steelworks, aluminium manufacturers, cement producers and other electricity-intensive EU consumers may therefore encounter CBAM-related costs through power procurement even when they are not the declarant.
Importers need compliance systems that can reconcile customs declarations with electricity scheduling data, generation information and contractual obligations. Power contracts also need to set out how future certificate purchases are financed, how carbon-related price adjustments are handled and which party obtains emissions information. The associated responsibilities span both compliance and commercial arrangements.
These requirements create a commercial incentive for Western Balkan exporters to provide EU counterparties with clear, reliable and independently verifiable electricity documentation. Competitiveness in cross-border trading increasingly depends on the price and origin of power, evidence of where it was generated and clarity about which entity carries the carbon obligation.
Regulation (EU) 2025/2083 and an OECD customs implementation analysis from October 2026 are cited as research references on CBAM implementation. As the first annual compliance deadline approaches, CBAM responsibilities are expected to feature more prominently in electricity procurement, contract pricing and counterparty selection throughout Southeast Europe.