Renewable electricity imported into the EU can be eligible for installation-specific actual emissions only when contractual, physical and scheduling requirements are met. The European Commission’s latest consolidated guidance states that renewable electricity does not automatically qualify for a zero or near-zero value under the Carbon Border Adjustment Mechanism (CBAM). As CBAM certificate costs rise, the guidance places emphasis on verifiable documentation for importers.
Installation-specific actual emissions depend on contractual and physical links
To use installation-specific actual emissions, the electricity must be covered by a power purchase agreement between the authorised CBAM declarant and the electricity producer in the third country. The generating installation must be directly connected to the EU transmission system. Alternatively, parties must demonstrate that no physical congestion existed between the installation and the Union network at the time of export.
The generating installation also has to meet an emissions threshold for fossil fuel sources. The guidance requires that it emit no more than 550 gCO2/kWh from fossil fuel inputs. Without meeting these conditions, renewable electricity cannot rely on an installation-specific actual-emissions approach.
Hourly nomination against interconnection capacity is required
For cross-border electricity trading, the guidance requires that the claimed quantity is firmly nominated against allocated interconnection capacity by responsible transmission system operators. The nominated capacity and electricity production must correspond to the same period. That period cannot exceed one hour.
The Commission’s guidance indicates that renewable energy certificates or a green electricity supply contract alone are not sufficient for eligibility under actual-emissions treatment. Instead, the claim must be supported by a qualifying contractual chain linking a named generating installation to the authorised CBAM declarant. It also requires acceptable physical and scheduling evidence.
Evidence requirements for Serbia and Montenegro exporters
For electricity exporters in Serbia and Montenegro, ordinary power-market records are described as important evidence for CBAM reporting. Importers seeking to use actual emissions rather than an applicable default emissions factor need to reconcile multiple data streams at hourly level.
The guidance lists production data from supervisory control and data acquisition (SCADA) systems and commercial metering as part of that reconciliation. It also includes nomination files, allocated interconnector capacity, congestion evidence and PPA terms. Whether imported renewable electricity’s emissions characteristics can be reflected in CBAM calculations depends on demonstrating this chain.
Certificate price reference and implications for imported electricity
The financial stakes increase as CBAM certificate prices rise. The European Commission set the reference price for the third quarter of 2026 at EUR 82.32 per tonne of CO2 equivalent. Electricity imported under CBAM does not receive a free-allocation adjustment because EU power generation generally does not receive free allowances under the EU Emissions Trading System.
The Commission’s guidance therefore describes a comparatively direct carbon-price signal for imported electricity. In cases where required cross-border matching cannot be demonstrated, importers may still face obligations calculated using applicable default emissions factors rather than installation-specific actual emissions.
PPA documentation becomes relevant for compliance reporting
For electricity producers and their EU customers, low physical emissions alone do not determine whether CBAM reporting can use actual emissions. The key factor is whether associated evidence meets CBAM requirements. If contractual, physical and scheduling elements cannot be verified, default factor calculations may apply.
For lenders and power buyers, the ability of a PPA to support CBAM-compliant reporting may become a commercially relevant attribute alongside electricity price, contracted volume and credit support. The guidance notes that low-emission generation does not guarantee a favourable CBAM outcome without documentation that can withstand verification.