EU customs statistics attributed 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 gross imports were reported at approximately €1.15 billion. The figures reflect trade flows and border attribution, not the Serbian generating units behind the electricity for carbon accounting under the EU Carbon Border Adjustment Mechanism (CBAM).
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.
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.
Customs attribution differs from CBAM installation-level emissions evidence
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 mechanism 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.
The role of industrial consumers in supply contracts does not make them the customs declarant. Using actual electricity emissions instead of prescribed default values is subject to strict regulatory conditions, and a standard renewable electricity purchase agreement or a guarantee of origin alone does not show that all CBAM requirements have been met.
Documentation needed to link volumes to generating installations
Linking a reported import to a generating installation requires matched generation-meter records, dispatch schedules, evidence of the contractual chain and nomination records. Public cross-border statistics do not identify the steelworks, chemical plant, factory or data centre that ultimately uses the electricity.
Establishing end-use would require supply and settlement data beyond customs totals. As a result, public border-attribution figures alone do not provide installation-level evidence needed to determine the emissions treatment of imported electricity under CBAM.
Serbia’s Ministry of Finance CBAM exposure estimates for 2026
Serbia’s Ministry of Finance modeled electricity-related CBAM exposure of €21.8 million in 2026 under a baseline scenario. The ministry noted that already-weaker trade flows could make the actual effect lower than that estimate.
Separate estimates were €20.7 million under a scenario excluding transit effects and around €14.5 million if proposed rules on Serbia’s national generation mix were adopted. The three figures are based on separate assumptions and are not cumulative costs or a regulatory concession already in force.
The ministry’s modeling also reflects that traders’ import economics depend on hourly market prices and congestion. An additional carbon charge can increase the minimum price difference needed to justify imports from a non-EU border, particularly during hours when EU renewable generation is abundant.
Evidencing chains and market conditions for import competitiveness
A portfolio that appears profitable before CBAM and transmission charges may become marginal once exposure to default emissions is included. One 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.
The ability to provide documentation may therefore affect competitiveness for Serbian exporters and their EU buyers alongside transmission capacity and wholesale prices. Available customs totals do not supply the installation-level evidence required to determine how imported electricity emissions are treated under CBAM.
Elevated by CBAM by Clarion Engineer