The European Commission has clarified that customs declarations for electricity imported into the European Union through explicitly allocated transmission capacity are tied to nominated quantities, with relevant hourly imports and exports taken into account. Published on 6 November, the operational guidance affects Serbian exporters and traders by making the reconciliation of commercial sales, transmission schedules and customs records central to documenting imports.
The guidance covers electricity imports under Centralised Clearance for Import, a customs procedure that allows import declarations to be handled through a centralised arrangement. It explains how the quantity imported into the EU should be identified and supported in customs records; it is not a new Carbon Border Adjustment Mechanism (CBAM) law.
Contracts and schedules must align
Serbia’s direct trading relationship with Hungary makes the clarification especially relevant. Serbian generators and suppliers can agree commercial delivery volumes in power purchase agreements, while traders or other intermediaries arrange transmission capacity and submit cross-border electricity schedules. The company that produces the electricity is not necessarily responsible for the EU import declaration.
Commercial sales, exchange trades and cross-border nominations can describe different parts of the same transaction. A Serbian supplier may sell output to a trader, which can combine volumes from several generators before scheduling an export. Traders need to reconcile their commercial positions with accepted transmission schedules and the quantities declared for EU customs purposes.
Without a clear allocation record, parties may have difficulty establishing which quantities were imported, who imported them and under which contract. Serbian traders should check that contracts identify the party responsible for cross-border nominations, customs formalities and CBAM declarations. Where different entities handle those functions, agreements should give the importer access to schedules, invoices and transmission-system records.
Carbon records remain separate
CBAM increases the financial consequences of weak records, but the customs guidance does not change Serbia’s electricity default factor or the conditions for using verified actual emissions. Serbia’s default factor is 1.041 tonnes of CO2 per megawatt-hour, and the CBAM certificate price for the third quarter of 2026 was €82.32 per tonne.
Using those figures produces an indicative unadjusted carbon amount of €85.70/MWh when the default factor applies. That calculation is not a universal export charge: an importer’s actual liability depends on applicable rules and adjustments. The guidance addresses how the imported quantity is established, not the emissions factor or eligibility to use verified actual emissions.
For a Serbian generator, the immediate risk identified in the guidance is a break in the evidence chain between electricity sold and electricity imported, rather than a new regulatory cost. A clear record can help an EU buyer establish the declared volume and evaluate a claim for plant-specific emissions. The guidance leaves wholesale price formation unchanged, while making customs reconciliation a more visible part of the route to market, particularly when several traders stand between a generating plant and the EU buyer.