Hungary and Romania accounted for nearly 7 TWh of the 9.845 TWh of gross electricity imports attributed to Serbia in 2025, according to EU customs statistics. The trade totals, valued at approximately €1.15 billion, do not identify which Serbian generating installations produced the electricity for the EU Carbon Border Adjustment Mechanism (CBAM).
Hungary reported 3.636 TWh of imports valued at approximately €427.8 million, and Romania reported 3.131 TWh valued at approximately €381.8 million. Bulgaria recorded 1.625 TWh worth approximately €190.4 million, while Croatia reported 1.254 TWh valued at approximately €130.1 million. The total was also reported in rounded form as 9.84 TWh and $1.30 billion, or roughly €1.15 billion at the 2025 average euro-dollar exchange rate.
The figures measure gross reported trade flows and border attribution, not Serbia’s net domestic power exports or independently verified electricity generation. Electricity can be scheduled across several borders and traded repeatedly, so an import attributed to Serbia does not establish that a particular Serbian generating unit supplied the megawatt-hours.
Customs records do not establish CBAM emissions
For carbon accounting, customs origin in trade statistics is not equivalent to a verified identity for the installation that generated the electricity. CBAM 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 electricity 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 prove that all conditions for actual-emissions treatment have been met.
Linking an imported megawatt-hour to a specific generating installation requires matched generation-meter records, dispatch schedules, evidence of the contractual chain and nomination records. Publicly accessible cross-border statistics also do not identify the steelworks, chemical plant, factory or data centre that ultimately consumes the electricity; that requires supply and settlement data.
Exposure estimates vary by scenario
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 exposure at €20.7 million under a scenario excluding transit effects.
The ministry considered exposure of around €14.5 million if proposed rules on the national generation mix were adopted. The €21.8 million, €20.7 million and around €14.5 million estimates reflect separate assumptions, not cumulative costs or a regulatory concession currently in force.
For electricity traders, import economics 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 during hours 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