Hungary and Romania together reported nearly 7 TWh of electricity imports attributed to Serbia in 2025, according to EU customs statistics, making them the largest of four EU markets in the data. The statistics recorded 9.845 TWh of gross imports worth approximately €1.15 billion, but do not establish which Serbian power plants generated the electricity for the EU Carbon Border Adjustment Mechanism (CBAM).
The total was also reported as 9.84 TWh and $1.30 billion, equivalent to roughly €1.15 billion at the 2025 average euro-dollar exchange rate. The reported flows measure gross trade and border attribution, not Serbia’s net domestic electricity exports or independently verified electricity generation.
Four markets reported imports
Hungary recorded 3.636 TWh valued at approximately €427.8 million. Romania reported 3.131 TWh worth approximately €381.8 million, while Bulgaria recorded 1.625 TWh valued at approximately €190.4 million and Croatia 1.254 TWh worth approximately €130.1 million.
Those customs figures do not trace the electricity to a particular Serbian generating unit. Electricity can be scheduled across several borders and traded repeatedly, so attribution to Serbia at a border does not by itself show which installation supplied an imported megawatt-hour.
Customs origin does not establish CBAM emissions
For CBAM purposes, the customs origin in trade statistics is not the same as a verified installation-level identity for emissions. CBAM covers electricity under CN 2716 00 00, while the cited trade figures 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 electricity 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 default values is subject to strict regulatory conditions. A standard renewable power purchase agreement or a guarantee of origin alone does not prove that all the conditions for actual-emissions treatment have been met.
Linking an import to a 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 models different exposure scenarios
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 €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 estimates reflect separate assumptions, not cumulative costs or a regulatory concession currently in force. The proposed rules on the national generation mix have not been presented as adopted.
Electricity 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 during hours when EU renewable generation is abundant. A trading portfolio that appears profitable before CBAM and transmission charges may become marginal once default-emissions exposure is applied.
A proposed practical remedy is an auditable evidence chain connecting 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