EU electricity importers must report embedded emissions and surrender Carbon Border Adjustment Mechanism (CBAM) certificates for power imported in 2026 by 30 September 2027, the first annual compliance deadline. The European Commission’s electricity-specific CBAM FAQ and guidance on the definitive regime and certificate calendar set out requirements that affect procurement and contract arrangements across Southeast Europe.
Electricity became a covered imported good when the definitive CBAM regime took effect on 1 January 2026. Importers must address customs declarations, carbon-accounting methodology and certificate obligations; unlike certain other CBAM goods, electricity is excluded from the general 50-tonne de minimis exemption, so smaller power transactions cannot use that threshold to avoid the requirements.
Purchases of certificates for 2026 electricity imports begin in February 2027, before the declaration and surrender deadline. That interval leaves importers with regulatory obligations before the related certificate settlement is completed, making the financing of future purchases, carbon-related price adjustments and responsibility for obtaining emissions information relevant to electricity contracts.
Declarants, origin and emissions evidence
The authorised CBAM declarant is generally the importer or an eligible indirect customs representative that assumes the applicable obligations. In qualifying cases where import capacity is explicitly allocated, the entity allocated and nominating that capacity and declaring the import to customs is treated as an authorised declarant without a separate authorisation application.
Electricity trades through interconnected networks, where commercial transactions, scheduled deliveries and physical power flows do not necessarily match a simple bilateral shipment. When power 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.
The origin rule and transit treatment are relevant to transactions involving Serbia, Montenegro and neighbouring EU markets, where power may pass through multiple counterparties and cross-border trading arrangements. Electricity 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 power imported for EU consumption.
Importers that seek to use actual emissions instead of default values must meet prescribed eligibility requirements and support their claims with appropriate evidence. This can include contractual records, production and metering data, transmission nominations and independent verification; the evidence must support the quantities and time periods claimed.
A renewable electricity certificate or a contractual statement describing power as green is not, on its own, sufficient to demonstrate compliance with every condition for using actual emissions. Emissions information must correspond to the relevant imports, and supporting records need to withstand regulatory scrutiny, including when power 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. An EU trader can be the declarant while a contract allocates the cost to a generator, intermediary or industrial customer, leaving the allocation to the parties’ commercial arrangements.
Steelworks, aluminium manufacturers, cement producers and other electricity-intensive EU consumers may encounter CBAM-related costs through power procurement even when they are not the declarant. Contracts need to address the financing of future certificate purchases, carbon-related price adjustments and which party obtains emissions information.
EU importers need compliance systems that reconcile customs declarations with electricity scheduling data, generation information and contractual obligations. The responsibilities also create a commercial incentive for Western Balkan exporters to provide EU counterparties with clear, reliable and independently verifiable electricity documentation.
Cross-border trading increasingly depends on the price and origin of power, evidence of where it was generated and clarity about 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 deadline approaches in 2027, CBAM responsibilities are expected to play a greater role in electricity procurement, contract pricing and counterparty selection throughout Southeast Europe.