Hungary and Romania together reported nearly 7 TWh of electricity imports attributed to Serbia in 2025, within a total of 9.845 TWh across four EU markets. EU customs statistics valued the gross flows at approximately €1.15 billion, also reported as $1.30 billion, but do not establish which Serbian generating installations produced the power for the European Union’s Carbon Border Adjustment Mechanism (CBAM).
Hungary recorded 3.636 TWh valued at approximately €427.8 million, and Romania reported 3.131 TWh worth approximately €381.8 million. Bulgaria’s reported imports were 1.625 TWh, valued at approximately €190.4 million, while Croatia recorded 1.254 TWh worth approximately €130.1 million.
The totals represent gross reported trade flows and border attribution, not Serbia’s net domestic electricity exports or independently verified electricity generation in the country. Electricity can be scheduled across several borders and traded repeatedly, so a border attribution alone does not show which generating unit produced a particular megawatt-hour.
Customs data do not establish CBAM emissions
Trade-statistics customs origin is not equivalent to a verified installation-level identity for emissions under CBAM. The mechanism covers electricity under CN 2716 00 00, whereas the trade figures use HS271600. The CBAM exemption for consignments below 50 tonnes does not apply to electricity.
The importing declarant must account for embedded emissions from imported electricity, and using actual emissions instead of prescribed default values is subject to strict regulatory conditions. 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 their supply contracts, but that does not make them the customs declarant. A standard renewable power purchase agreement or a guarantee of origin alone does not demonstrate that all conditions for actual-emissions treatment have been met.
Connecting an imported megawatt-hour to a specific Serbian generating installation requires matched generation-meter records, dispatch schedules, evidence of the contractual chain and nomination records. Identifying the steelworks, chemical plant, factory or data centre that ultimately consumes the power also requires supply and settlement data beyond publicly accessible cross-border statistics.
Exposure estimates depend on assumptions
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 €20.7 million under a scenario excluding transit effects.
The ministry also considered exposure of around €14.5 million if proposed rules on the national generation mix were adopted. The three estimates reflect separate assumptions; they are not cumulative costs or a regulatory concession currently guaranteed to importers.
Electricity 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 portfolio that appears profitable before CBAM and transmission charges may become marginal once 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