Hungary and Romania together reported nearly 7 TWh of electricity imports attributed to Serbia in 2025, most of the 9.845 TWh recorded across four EU markets. EU customs statistics valued the gross imports at approximately €1.15 billion. The figures do not establish which Serbian power plants generated the electricity for carbon accounting under the EU Carbon Border Adjustment Mechanism (CBAM).
Hungary recorded 3.636 TWh, 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.
These totals represent reported gross trade flows and border attribution, not Serbia’s net domestic electricity exports or independently verified generation. Electricity can be scheduled across multiple borders and traded repeatedly. A customs record attributing an import to Serbia therefore does not show that a specific Serbian generating unit supplied the megawatt-hours.
Trade attribution does not identify CBAM emissions
For CBAM purposes, the customs origin in trade statistics is not equivalent to 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, that obligation formally falls to 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 rather than prescribed default values is subject to strict regulatory conditions. A standard renewable power purchase agreement or a guarantee of origin alone does not establish that all those conditions have been met. 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 consumes the electricity. Identifying the end user would require supply and settlement data.
Exposure estimates and import economics
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 in a scenario excluding transit effects, and around €14.5 million if proposed rules on the national generation mix were adopted. The three estimates reflect separate assumptions, not cumulative costs or a regulatory concession already in force.
For traders, electricity import economics also depend on hourly market prices and congestion. An additional carbon charge can increase the minimum price difference required to justify imports from a non-EU border, particularly in 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.
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, 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 imported electricity.
Elevated by CBAM by Clarion Engineer