EU electricity importers must account for embedded emissions and surrender Carbon Border Adjustment Mechanism (CBAM) certificates for power imported in 2026, with the first annual declaration and surrender due by 30 September 2027. The European Commission’s electricity-specific CBAM FAQ and information on the definitive regime and certificate calendar set out obligations affecting power procurement and contracts across Southeast Europe.
Electricity became a covered imported good when the definitive CBAM regime took effect on 1 January 2026. Importers must address customs declarations, carbon-accounting methodology and certificate obligations. Electricity is excluded from the 50-tonne de minimis exemption available for certain other CBAM goods, meaning smaller electricity transactions cannot use that threshold to opt out.
Declarations and responsibility for certificates
Purchases of CBAM certificates for electricity imported in 2026 begin in February 2027, before the annual declaration and surrender deadline. Importers therefore face regulatory obligations before the associated certificate settlement is completed. Electricity contracts need to address financing future certificate purchases, carbon-related price adjustments and responsibility for obtaining emissions information.
Under the Commission’s guidance, the authorised CBAM declarant is generally the importer or an eligible indirect customs representative that assumes the applicable obligations. In qualifying cases where electricity import capacity is explicitly allocated, the entity allocated and nominating that capacity and declaring the import to customs is treated as an authorised CBAM declarant without a separate authorisation application.
Electricity moves through interconnected networks, where commercial transactions, scheduled deliveries and physical power flows do not necessarily correspond to a simple bilateral shipment. In the Western Balkans and neighbouring EU markets, power may be sold through several counterparties and cross-border trading arrangements, making it necessary to reconcile customs declarations and emissions information with the relevant imports.
Country of origin and emissions evidence
When electricity is produced in one non-EU country, traded through another and then enters the EU, its CBAM country of origin is the country of production, not automatically the intermediate trading country. The rule is particularly relevant to transactions involving Serbia, Montenegro and neighbouring EU markets. Electricity that enters and leaves the EU under an applicable customs transit procedure without being released for free circulation is not treated in the same way as electricity imported for EU consumption.
Importers seeking to use actual emissions instead of default values must meet prescribed eligibility requirements. Their claims must be supported by appropriate contractual evidence, production and metering records, transmission nominations and independent verification. The evidence must cover the quantities and time periods being claimed, and CBAM emissions information must match the relevant electricity imports.
A renewable electricity certificate or a contractual statement describing power as green is not sufficient on its own to demonstrate compliance with every condition for using actual emissions. Importers need supporting records that can withstand regulatory scrutiny, including where electricity has passed through several trading and transmission arrangements.
Contract costs and market documentation
The legal CBAM declarant and the party bearing the carbon-related financial cost may differ under electricity contracts. An EU trader may be the declarant while a contract allocates the cost to a generator, intermediary or industrial customer. Steelworks, aluminium manufacturers, cement producers and other electricity-intensive EU consumers buying imported power may therefore encounter CBAM-related costs through procurement arrangements even when they are not the declarant.
Contracts need to specify how future certificate purchases are financed, how carbon-related price adjustments are handled and which party obtains emissions information. EU importers also need compliance systems that reconcile customs declarations with electricity scheduling data, generation information and contractual obligations.
These responsibilities create a commercial incentive for Western Balkan exporters to give EU counterparties clear, reliable and independently verifiable electricity documentation. In cross-border trading, competitiveness increasingly depends on the price and origin of power, evidence of where it was generated and clarity over which entity carries the carbon obligation. As the first annual compliance deadline approaches, CBAM responsibilities are expected to become more important in electricity procurement, contract pricing and counterparty selection throughout Southeast Europe.
Regulation (EU) 2025/2083 and an OECD customs implementation analysis from October 2026 are cited as research references concerning CBAM implementation.