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 information on the definitive regime and certificate calendar set out obligations affecting procurement and contracts across Southeast Europe.
Electricity became a covered imported good when the definitive CBAM regime took effect on 1 January 2026. Importers must consider customs declarations, carbon-accounting methodology and certificate obligations. Unlike certain other CBAM goods, electricity is excluded from the 50-tonne de minimis exemption, so smaller electricity transactions cannot use that threshold to avoid the requirements.
Purchases of certificates for 2026 imports begin in February 2027, months before the annual declaration and surrender deadline. The interval means importers face regulatory obligations before completing the associated certificate settlement. Electricity contracts therefore need to address financing future certificate purchases, carbon-related price adjustments and responsibility for obtaining emissions information.
Declarant, origin and emissions evidence
The authorised CBAM declarant is generally the importer or an eligible indirect customs representative that takes on the applicable obligations. 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 in qualifying cases without a separate authorisation application.
Electricity trades through interconnected networks, where commercial transactions, scheduled deliveries and physical flows do not necessarily amount to a simple bilateral shipment. If electricity is produced 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. These origin rules are particularly relevant to transactions involving Serbia, Montenegro and neighbouring EU markets.
Electricity in the Western Balkans and neighbouring EU markets can be sold through multiple counterparties and cross-border arrangements. Power 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.
Importers seeking to use actual emissions instead of default values must meet prescribed eligibility requirements and provide supporting evidence. This can include contracts, production and metering records, transmission nominations and independent verification. Evidence must support the quantities and time periods claimed, while 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 must keep records capable of withstanding regulatory scrutiny, including where electricity has moved through several trading and transmission arrangements.
Contract costs and compliance systems
The legal CBAM declarant and the party carrying the carbon-related financial cost may differ under a power contract. An EU trader can be the declarant while the contract allocates the cost to a generator, intermediary or industrial customer. Steelworks, aluminium manufacturers, cement producers and other electricity-intensive EU consumers may thus encounter CBAM-related costs through power procurement even when they are not the declarant.
Importers need systems that reconcile customs declarations with electricity scheduling data, generation information and contractual obligations. Contracts also need to specify how certificate purchases are financed, how carbon-related price adjustments are handled and which party obtains emissions information. These responsibilities give Western Balkan exporters a commercial incentive to provide EU counterparties with clear, reliable and independently verifiable documentation.
Cross-border trading increasingly depends on power prices and origin, as well as evidence of where electricity was generated, what was imported and which entity carries the carbon obligation. Regulation (EU) 2025/2083 and an OECD customs implementation analysis from October 2026 are cited as research references on CBAM implementation. As the first annual compliance deadline approaches, CBAM responsibilities are expected to become more important to electricity procurement, contract pricing and counterparty selection throughout Southeast Europe.