Identifying the generating source of electricity delivered to EU markets is difficult when power crosses several control areas. EU mirror statistics recorded 9.84 TWh of gross electricity imports reported from Serbia in 2025, but those figures do not establish where the electricity was generated.
Hungary, Romania, Bulgaria and Croatia were the leading destinations for the reported imports. Serbian border figures may include domestic generation, bilateral purchases, transit flows and re-exported electricity, so they do not identify the origin of each megawatt-hour.
Electricity from Montenegro, Bosnia and Herzegovina, North Macedonia or Albania can enter wholesale positions and cross-border schedules involving Serbia before reaching an EU market. Physical flows, the contractual seller and customs origin are distinct, meaning that attributing all electricity imported from Serbia to Serbian generating installations would misrepresent the region’s carbon burden.
Emissions evidence and CBAM requirements
In an assessment published in June 2026, Serbia’s Ministry of Finance estimated electricity-related exposure of around 21.8 million euros for 2026, based on its original baseline. The ministry said regulatory uncertainty may already be affecting cross-border power trading across borders, and cautioned that assuming 2025 volumes remain unchanged provides a weak basis for estimating future liabilities.
The ministry considered possible regulatory changes that could reduce the modeled effect on electricity, but said these had not been adopted when it conducted its assessment. The impact of compliance on trading volumes will also depend on market conditions.
Electricity is not covered by the Carbon Border Adjustment Mechanism’s (CBAM) 50-tonne physical-goods exemption and is fully exposed from the start of the definitive regime, subject to detailed accounting rules and specific exemptions. The EU allows verified actual-emissions approaches only under demanding conditions, including direct electricity sourcing, contractual and physical matching, and access to the network.
A power portfolio combining hydro, wind, solar, coal and imported electricity may require a reconciled chain of evidence to support an emissions claim for a specific installation. Renewable guarantees of origin serve a separate market function and do not automatically replace the evidence required under CBAM.
Trading economics and evidence for exports
For a trader buying lower-cost electricity outside the EU for sale in Hungary or Romania, exchange prices are only one component of the calculation. Border congestion, transmission costs, balancing obligations, carbon certificates and the credit needed to hold positions can wipe out otherwise positive trading spreads, particularly when EU solar or wind generation pushes domestic prices down.
Regional renewable developers can base export opportunities on a verifiable evidence chain rather than a general green claim. Installation-level metering, clear asset ownership, power-purchase contracts, hourly schedules, identification of the EU importer and controlled allocation of environmental attributes can help reduce disputes.
The same records may support bank lenders’ assessments of long-term contracted revenue, although the legal route for recognition of actual emissions requires confirmation in each case. The central regional policy question is whether a specific megawatt-hour can be lawfully linked to a specific installation and importing declarant, rather than relying only on a country’s average carbon intensity.
Elevated by CBAM by Clarion Engineer
