Electricity imports into the European Union are developing into a carbon-compliance market as CBAM assigns a financial consequence to emissions associated with imported power. Under the regime, generators and traders may benefit if they can document qualifying physical electricity supplies and substantiate emissions claims.
The European Commission’s transitional registry recorded approximately 96 million MWh of electricity imports between the fourth quarter of 2023 and the second quarter of 2025. The United Kingdom accounted for around 65% of the reported volume, followed by Serbia at 15% and North Macedonia at 5.2%. Bosnia and Herzegovina and Montenegro were also among the principal countries of origin.
These figures reflect historical declaration shares during the transitional period rather than audited market shares for 2026. They provide a basis for understanding how declarations were handled before the definitive CBAM rules apply to imported electricity.
Default emissions factors dominate transitional electricity declarations
During the analysed transitional period, around 97% of electricity declarations relied on default emissions factors instead of data specific to actual electricity generation. The European Commission estimated that the reported imports corresponded to approximately 86 million tonnes of CO₂ equivalent. The Commission also cautioned that defaults based on fossil-fuel generation can overstate embedded emissions for some electricity flows.
The Commission’s estimate is not presented as a measurement of emissions from every imported megawatt-hour. It instead highlights how the emissions calculation methodology can affect results when generation-specific evidence is unavailable or does not meet applicable requirements.
With the definitive CBAM regime in place, establishing the correct emissions treatment can influence the carbon cost applied to imported electricity. The reference price for the third quarter of 2026 reached €82.32 per tonne of CO₂ equivalent, according to the information cited in the transitional context.
Actual-emissions claims depend on contractual and physical delivery evidence
Whether an authorised declarant applies a default value or substantiates actual emissions from a qualifying generating installation can lead to substantially different carbon costs for imported electricity. The conditions for using actual emissions values are described as specific under the applicable legal framework.
The framework requires a qualifying power purchase agreement between the authorised EU declarant and a third-country electricity producer, or a permitted intermediary arrangement. Evidence must also address physical connectivity or the absence of network congestion at export time, assessed on an hourly basis.
Metering records, transmission schedules, contractual allocation, and a defensible link between the generating installation and the imported electricity are identified as commercially important. A guarantee of origin or a general claim that a trader purchased renewable electricity is not sufficient on its own for meeting these CBAM-specific conditions.
The same traceability requirement applies when low emissions occur at a plant but electricity moves through a trading chain that cannot be adequately traced. Eligibility for actual-emissions treatment depends on demonstrating connections between generation, contractual arrangements, and physical delivery.
Commission proposals on attribution do not change 2026 obligations
The European Commission has proposed changes to electricity-emissions attribution as part of its wider downstream CBAM package. The proposals aim, among other things, to improve treatment of decarbonisation outside the EU, but they remain subject to legislative negotiations.
The reform is described as not an existing entitlement, meaning importers must apply rules currently in force when preparing their 2026 CBAM declarations. Anticipated future flexibility cannot justify an emissions calculation unless changes have been adopted and become applicable.
For generators in the Western Balkans, the described compliance requirements may support supply products combining electricity delivery with appropriate contractual structures and verifiable evidence connecting generating installations to the EU border. The distinction is noted as potentially relevant to wind, solar and hydropower producers, including developers exploring storage-linked supply strategies.
Banks evaluating such projects are expected to distinguish between a megawatt-hour that can be physically traded across borders and one that meets legal conditions for an actual-emissions claim under CBAM. Competitive outcomes are described as dependent on whether exporters and authorised EU declarants can demonstrate precise conditions supporting claimed carbon treatment.