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 guidance on the definitive regime and certificate calendar set out obligations relevant to procurement and contracts across Southeast Europe.
Electricity became a covered imported good when the definitive CBAM regime took effect on 1 January 2026, according to the Commission. 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, so smaller electricity transactions cannot use that threshold to opt out.
Declaration, certificates and responsibility
Purchases of CBAM certificates for electricity imported in 2026 begin in February 2027, ahead of the annual declaration and surrender deadline. That interval leaves importers with regulatory obligations before the associated certificate settlement is completed, making the financing of future certificate purchases, carbon-related price adjustments and responsibility for emissions information relevant to contract terms.
The authorised CBAM declarant is generally the importer or an eligible indirect customs representative that assumes the applicable obligations, under the Commission’s guidance. 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 declarant without a separate authorisation application.
Electricity trading takes place through interconnected networks, where commercial transactions, scheduled deliveries and physical power flows do not necessarily match a simple bilateral shipment. In the Western Balkans and neighbouring EU markets, power may pass through multiple counterparties and cross-border arrangements, complicating the task of matching customs declarations and emissions information to the relevant imports.
Origin and emissions evidence
Where electricity is generated 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. That 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. The distinction matters in cross-border arrangements because physical flows, scheduled deliveries and commercial trades may not describe the same bilateral movement.
Importers that seek to use actual emissions instead of default values must meet prescribed eligibility requirements and support their claims with appropriate contractual evidence, production and metering records, transmission nominations and independent verification. The evidence must support the quantities and time periods being claimed, and emissions information must correspond to 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 when electricity has moved through several trading and transmission arrangements.
Contract costs and market documentation
The legal CBAM declarant and the party carrying 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 that buy imported power may therefore encounter CBAM-related costs through procurement arrangements even when they are not the declarant. Contracts need to address how future certificate purchases are financed, how carbon-related price adjustments are handled and which party obtains emissions information.
EU importers need compliance systems that can reconcile customs declarations with electricity scheduling data, generation information and contractual obligations. The expanding responsibilities also create a commercial incentive for Western Balkan exporters to provide EU counterparties with clear, reliable and independently verifiable electricity documentation.
In cross-border electricity 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 play a greater role 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.
