EU customs statistics attributed 9.845 TWh of electricity imports to Serbia across four EU markets in 2025, with Hungary and Romania accounting for nearly 7 TWh combined. The reported gross imports were valued at approximately €1.15 billion. These figures show trade flows and border attribution, but not which Serbian power plants generated the electricity for carbon accounting under the EU Carbon Border Adjustment Mechanism (CBAM).
Hungary recorded 3.636 TWh of imports, worth approximately €427.8 million, while Romania reported 3.131 TWh, valued at approximately €381.8 million. Bulgaria recorded 1.625 TWh worth approximately €190.4 million, and Croatia reported 1.254 TWh valued at approximately €130.1 million.
The reported totals are gross trade flows, not Serbia’s net domestic electricity exports or independently verified generation. Electricity can be scheduled across multiple borders and traded more than once, so a customs record attributing an import to Serbia does not prove that a specific Serbian generating unit supplied those megawatt-hours.
Trade records do not verify CBAM emissions
For CBAM, the customs origin in trade statistics is not the same as a verified identification of the installation that generated the electricity. The mechanism covers electricity under CN 2716 00 00, whereas the cited trade data use HS271600. The exemption for consignments below 50 tonnes does not apply to electricity.
The EU importing declarant is responsible for accounting for embedded emissions from imported electricity. For imports into Hungary and Romania, this responsibility formally falls to the authorised EU declarant, which may be an electricity trader, supplier or another eligible importing entity. Industrial consumers may face higher prices indirectly through supply contracts, but that does not make them the customs declarant.
Using actual electricity emissions rather than prescribed default values is subject to strict regulatory conditions. A standard renewable electricity purchase agreement or a guarantee of origin on its own does not demonstrate that all of those conditions have been met under the CBAM requirements.
Linking a reported import to a generating installation requires matched generation-meter records, dispatch schedules, evidence of the contractual chain and nomination records. Public cross-border statistics also do not identify the steelworks, chemical plant, factory or data centre that ultimately uses the electricity; that would require supply and settlement data.
Serbia’s estimates vary by scenario
Serbia’s Ministry of Finance modeled electricity-related CBAM exposure of €21.8 million in 2026 under a baseline scenario, while noting that already-weaker trade flows could make the actual effect lower. Its separate estimates were €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 ministry’s three figures are based on separate assumptions; they are not cumulative costs or a regulatory concession already in force. For traders, the economics of electricity imports also depend on hourly market prices and congestion. An additional carbon charge can increase the minimum price difference needed to justify imports from a non-EU border, particularly during hours when EU renewable generation is abundant.
A portfolio that appears profitable before CBAM and transmission charges may become marginal once exposure to default emissions is included. One proposed practical remedy is an auditable evidence chain linking each imported volume and its EU declarant with the generating installation, metering, dispatch and cross-border schedule.
For Serbian exporters and their EU buyers, the ability to provide documentation may therefore matter to maintaining competitiveness alongside transmission capacity and wholesale prices. The available customs totals alone do not provide the installation-level evidence needed to determine the actual emissions treatment of the imported electricity.
Elevated by CBAM by Clarion Engineer
