Hungary and Romania together accounted for nearly 7 TWh of electricity imports attributed to Serbia in 2025, within a total of 9.845 TWh reported across four EU markets. EU customs statistics valued the gross imports at approximately €1.15 billion, also reported as $1.30 billion, but the figures do not identify the Serbian generating installations relevant to the EU Carbon Border Adjustment Mechanism (CBAM).
Hungary reported 3.636 TWh valued at approximately €427.8 million, while Romania recorded 3.131 TWh worth approximately €381.8 million, according to the statistics. Bulgaria reported 1.625 TWh valued at approximately €190.4 million, and Croatia recorded 1.254 TWh worth approximately €130.1 million.
The figures measure gross reported trade flows and border attribution, not Serbia’s net domestic electricity exports or independently verified generation in Serbia. Electricity can be scheduled across several borders and traded repeatedly, so attribution at a border does not establish which generating unit produced a given megawatt-hour.
Customs origin does not establish CBAM emissions
For CBAM, the customs origin in trade statistics is not equivalent to a verified, installation-level identity for emissions. The mechanism covers electricity under CN 2716 00 00, while the cited trade data use HS271600. The exemption for consignments below 50 tonnes does not apply to electricity.
The importing declarant must account for embedded emissions from imported electricity. For imports into Hungary and Romania, the formal obligation rests with the authorised EU declarant, which may be an electricity trader, supplier or another eligible importing entity. Industrial users may face higher prices indirectly through supply contracts, but that does not make them the customs declarant.
Using actual electricity emissions instead of prescribed defaults is subject to strict regulatory conditions. A standard renewable power purchase agreement or a guarantee of origin alone does not prove that all requirements for actual-emissions treatment have been met.
Linking an imported megawatt-hour to a specific Serbian generating installation requires matched generation-meter records, dispatch schedules, evidence of the contractual chain and nomination records. Identifying the steelworks, chemical plant, factory or data centre that ultimately uses the electricity also requires supply and settlement data beyond publicly accessible cross-border statistics.
Ministry estimates vary with assumptions
Serbia’s Ministry of Finance modeled electricity-related CBAM exposure at €21.8 million in 2026 under a baseline scenario, while warning that already-weaker trade flows could make the actual effect lower. It separately estimated exposure at €20.7 million under a scenario excluding transit effects, and around €14.5 million if proposed rules on the national generation mix were adopted.
The three estimates use separate assumptions; they are not cumulative costs or a regulatory concession currently guaranteed to importers. The national-generation-mix rules remain proposed in the facts provided.
For traders, import economics respond to hourly market prices and congestion. An additional carbon charge can widen the minimum price difference needed to justify imports from a non-EU border, particularly when EU renewable generation is abundant. A trading portfolio that appears profitable before CBAM and transmission charges may become marginal when default-emissions exposure is included.
A proposed practical remedy is an auditable evidence chain linking each imported volume and its EU declarant to the generating installation, metering, dispatch and cross-border schedule. For Serbian exporters and their EU buyers, documentary capability may matter to maintaining competitiveness alongside transmission capacity and wholesale electricity prices.
Elevated by CBAM.Clarion Engineer
