Hungary and Romania together reported nearly 7 TWh of electricity imports attributed to Serbia in 2025, accounting for most of the 9.845 TWh recorded across four EU markets. EU customs statistics valued the gross imports at approximately €1.15 billion; the same total was also reported as 9.84 TWh worth $1.30 billion, or roughly €1.15 billion at the 2025 average euro-dollar exchange rate. The figures do not establish which Serbian power plants produced the electricity for 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. Bulgaria reported 1.625 TWh valued at approximately €190.4 million, and Croatia 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. Electricity can be scheduled across several borders and traded repeatedly, meaning customs attribution alone does not show that a particular Serbian generating unit supplied a given megawatt-hour.
Linking an imported volume 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 consumes the electricity; that would require supply and settlement data.
Customs records do not establish CBAM emissions
For CBAM, 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 CBAM importer 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 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 requirements for actual-emissions treatment have been met.
Ministry estimates vary by scenario
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 three figures represent separate assumptions, not cumulative costs or a regulatory concession currently in force. The ministry’s estimates do not change the requirement for the importing declarant to account for embedded emissions under the applicable rules.
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 portfolio that appears profitable before CBAM and transmission charges may become marginal when 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 be as important to maintaining competitiveness as transmission capacity or wholesale electricity prices.
Elevated by CBAM.Clarion Engineer