Proposed changes to the EU’s electricity-related CBAM rules could affect how Western Balkan electricity exports are assessed by changing default emissions factors and modifying requirements for demonstrating actual emissions.
An analysis published by Karanovic & Partners on 14 September highlighted the potential significance of the European Commission’s proposal for electricity exporters. The measures remain under negotiation and do not replace the rules currently applicable to compliance.
Generation mix could influence default factors
One proposed change concerns how the exporting country’s electricity generation mix is reflected in the default calculation. Instead of relying primarily on fossil-fuel generation, the revised approach would also take non-fossil generation into account.
The change could be particularly relevant for electricity systems combining renewable and thermal generation, including those in the Western Balkans. A revised national default factor would nevertheless remain a regulatory calculation and would not demonstrate that an individual shipment originated from a specific low-carbon power plant.
The distinction is important for exporters seeking to connect the characteristics of their electricity systems with the carbon cost applied at the EU border.
Proposed changes to actual-emissions evidence
The Commission is also proposing changes affecting how exporters can demonstrate actual emissions. These include physical power-purchase agreements involving intermediaries, alongside proposals to remove or ease certain existing requirements concerning network connection, congestion and capacity nomination.
The proposed changes should not be interpreted as making every electricity contract or renewable-energy certificate sufficient evidence of actual emissions.
A qualifying physical contractual chain remains distinct from a claim concerning the environmental attributes of electricity. The evidence supporting delivery and generation therefore remains commercially important.
Existing rules remain applicable
The Commission’s guidance for the current definitive period continues to distinguish the requirements already in force from the changes being negotiated.
Producers and electricity traders therefore need to assess existing deliveries under the enacted CBAM framework, while separately evaluating how a revised methodology could affect future contracts.
For Western Balkan exporters, the proposed changes could create a closer connection between demonstrable generation characteristics and the carbon costs associated with electricity entering the EU. Whether that connection can be applied in practice will depend on the final legislation and on whether contracts, generation data and delivery evidence can be linked without gaps.
