The European Commission is proposing a change to the EU Carbon Border Adjustment Mechanism (CBAM) that could increase the commercial relevance of national electricity-grid decarbonisation. Under COM(2025) 989, the Commission would revise the default-emissions methodology for imported electricity. The proposal includes moving toward an average grid emissions factor rather than a factor based only on fossil sources that set electricity prices.
If adopted, the revised approach could affect the relative economics of electricity imports from countries expanding renewable generation. The default calculation could reflect grid decarbonisation more directly. This could reduce the gap between imports assessed under default values and those that qualify for installation-specific actual emissions values.
Current CBAM coverage for imported electricity
The definitive CBAM regime has been in place since 1 January 2026. Electricity is covered under CN 2716 00 00. The mass-based de minimis exemption introduced through the 2025 simplification does not remove electricity imports from the mechanism.
For 2026 imports, certificate sales are scheduled to start on 1 February 2027. The first annual declaration and certificate-surrender deadline is 30 September 2027. From 2027, the general certificate-pricing mechanism moves to weekly averaging of auction prices, and quarterly holding requirements become part of the treasury cycle.
Companies therefore need to plan for CBAM financial impacts while separating compliance timing from any future regulatory changes. This includes preparing for obligations that apply under the rules currently in force. It also requires attention to when certificate-related processes begin and when declarations must be submitted.
Implications for Western Balkan electricity exports and industry
The proposed methodology has implications beyond electricity trading for Western Balkan countries. Faster renewable deployment, coal displacement, and improved grid integration are cited as factors that could influence carbon competitiveness of electricity exports. The same developments could affect investment cases for power-intensive industries, including steel and aluminium.
A lower national grid emissions factor could become more commercially relevant if the final CBAM rules incorporate average grid emissions into the default route. The potential scale of any advantage would depend on the methodology ultimately adopted. It would also depend on country-specific values applicable to the relevant reporting period.
Planning ahead without assuming future methodology changes
The guidance in the proposal’s context indicates that companies should not build proposed emissions factors into base-case financial models before the revised methodology is legally adopted. It also notes that applicable country values should be published before such assumptions are used. Sensitivity analysis is presented as an alternative way to test how different grid-emissions assumptions might affect electricity costs and export competitiveness.
The same approach is described for treasury and investment decisions. Carbon-price hedges, electricity contracts, and capital expenditure may need to be arranged before legislative outcomes are known. Accounting and compliance treatment should remain anchored in the rules currently in force.
Flexible contract structures and retained source data are identified as tools that can support faster responses once final methodology details are available. This is described as a way to preserve options related to regulatory changes without prematurely recognising an expected benefit. It also aligns decision-making with information available under current-law requirements.
Commission guidance on implementation timeline
The European Commission published definitive-period sector guidance on 14 August 2026. The package included dedicated guidance for electricity, iron and steel, and aluminium. The Commission refreshed its general CBAM questions and answers on 15 October 2026.
The materials are described as explaining implementation while not replacing binding regulation and implementing acts. For policy-sensitive investments, the governing principle described is maintaining flexibility for reform while keeping current-law controls until an adopted rule changes them. A cleaner national grid is referenced as potentially becoming a trade asset, but only the enacted CBAM methodology determines what is recognised at the EU border.