The European Commission’s latest consolidated guidance states that renewable electricity imported into the EU does not automatically qualify for a zero or near-zero value under the Carbon Border Adjustment Mechanism (CBAM). Importers seeking to apply installation-specific actual emissions must meet a cumulative set of requirements. The guidance links eligibility to contractual, physical, and scheduling evidence.
Conditions for installation-specific actual emissions
To claim installation-specific actual emissions, the electricity must be covered by a power purchase agreement (PPA) between the authorised CBAM declarant and the electricity producer in the third country. The generating installation must be directly connected to the EU transmission system. Alternatively, the parties must show that no physical congestion existed between the installation and the Union network at the time of export.
The generating installation also has to meet a fossil emissions threshold. The guidance requires that it emits no more than 550 gCO₂/kWh from fossil fuel sources. These conditions are presented as part of a single, cumulative eligibility framework for actual-emissions treatment.
Hourly cross-border matching requirements
For cross-border electricity trading, the guidance requires that the claimed quantity is firmly nominated against allocated interconnection capacity by the responsible transmission system operators. The nominated capacity and the electricity production must relate to the same period. That period cannot exceed one hour.
The Commission’s guidance indicates that renewable energy certificates or a green electricity supply contract alone are not sufficient for actual-emissions eligibility. Instead, claims must be supported by a contractual chain connecting a named generating installation to the authorised CBAM declarant. The chain also needs to be accompanied by acceptable physical and scheduling evidence.
Evidence expectations for Serbia and Montenegro exporters
For electricity exporters in Serbia and Montenegro, ordinary power-market records are identified as relevant evidence for CBAM reporting. Importers seeking actual emissions rather than using an applicable default emissions factor need to reconcile multiple data streams at hourly level. These include production data from supervisory control and data acquisition (SCADA) systems and commercial metering.
The guidance also points to nomination files, allocated interconnector capacity, congestion evidence, and PPA terms as part of the hourly reconciliation process. Demonstrating this chain is described as determining whether the emissions characteristics of imported renewable electricity can be reflected in CBAM calculations.
Certificate price reference and implications for contracting
The financial stakes are described as increasing alongside higher CBAM certificate prices. The European Commission set the reference price for the third quarter of 2026 at EUR 82.32 per tonne of CO₂ equivalent. The guidance notes that electricity does not receive a free-allocation adjustment because EU power generation generally does not receive free allowances under the EU Emissions Trading System.
As a result, the carbon-price signal for imported electricity is described as comparatively direct in relation to CBAM costs. For electricity producers and EU customers, the key issue is whether evidence meets CBAM requirements rather than whether generation has low physical emissions.
PPA suitability for CBAM reporting
If cross-border matching cannot be demonstrated, an importer may still face an obligation calculated using the applicable default emissions factor. For lenders and power buyers, whether a PPA can support CBAM-compliant reporting may become a commercially relevant attribute alongside electricity price, contracted volume, and credit support.
The guidance further states that low-emission generation alone does not guarantee a favourable CBAM outcome if contractual, physical, and scheduling evidence cannot withstand verification. In such cases, eligibility for installation-specific actual emissions depends on meeting all required documentation and matching conditions.