The European Commission’s 8 June 2026 DG TAXUD publication on indirect emissions in CBAM addresses three areas: operational default emission factors, the conditions for claiming actual indirect emissions through direct technical links, PPAs and verification, and whether indirect-emissions coverage could extend to additional CBAM sectors. For Serbia, the publication is relevant to how electricity used in production is evidenced for trade into the EU. Serbian electricity is expected to be assessed not only on price but also on carbon traceability.
Serbian power producers, traders and renewable developers are expected to prepare electricity products that can be documented, allocated and verified for use by EU importers within their CBAM files. The focus extends to EPS, private renewable developers, electricity traders, industrial suppliers and exporters using electricity-intensive production. The market signal also targets steel processors, cement producers, fertiliser and chemical companies, and aluminium-related processors.
DG TAXUD guidance on indirect emissions and evidence requirements
The DG TAXUD direction links the possibility of claiming actual indirect emissions with PPAs, direct technical links and verification. It also sets out how operational default emission factors may be used when actual claims are not supported. This connection affects how electricity procurement is structured for exporters selling into the EU.
For Serbia’s EU-facing industrial exporters, a key question is whether they can prove the carbon profile of the electricity used to produce goods sold into the EU. If an exporter cannot support actual indirect-emissions claims, the EU importer or authorised CBAM declarant may need to rely on default factors. Weak electricity evidence can therefore affect the commercial value of goods even when other cost drivers remain competitive.
Electricity procurement as audit-ready compliance
Serbian exporters may need to design electricity procurement as an audit-ready compliance system rather than only as a supply arrangement. The approach depends on whether actual indirect emissions can be supported under DG TAXUD conditions. This shifts attention toward documentation that can be checked in CBAM processes.
In practical terms, the evidence chain must connect electricity sourcing and consumption with the claim being made in CBAM reporting. That includes defining what can be claimed through contractual structures such as PPAs and what requires verification. The evidence needs to be usable by EU importers inside their CBAM documentation.
Documentation packages for Serbian renewable projects
Serbian power producers, particularly renewable developers, are expected to prepare electricity products with a full documentation package. For wind or solar projects selling to an industrial exporter, this includes generation data and metering evidence. It also covers plant identification and grid connection documentation.
The documentation package is expected to include guarantee-of-origin or equivalent certificate records, settlement data and curtailment logs. It should also specify clear rules on who may claim the low-carbon attribute associated with the electricity supply. These elements support traceability for downstream reporting needs.
For Serbian wind and solar developers, a CBAM-exposed industrial buyer may become a stronger offtaker when contracts help protect EU market access. In this setup, a PPA functions beyond generator revenue by becoming part of export-compliance architecture. A renewable project with a CBAM-relevant industrial PPA could also improve its commercial case with lenders if the contract is credible, long-term, metered and properly documented.
CBAM-ready electricity packs from Serbian traders
Serbian electricity traders are expected to move from standard supply and balancing services toward CBAM-ready electricity products. A trader serving an industrial exporter needs to manage physical or contractual supply alongside renewable sourcing and balancing arrangements. The trader also needs to handle residual electricity where renewable supply does not cover load.
The trader’s role extends to certificates, metered consumption and reporting periods, together with importer-facing documentation. The structure described is compliance-grade energy supply rather than normal commodity trading. Monthly reporting is positioned as central to this approach.
The best-positioned traders would provide monthly CBAM electricity packs showing volume supplied, source origin and contract basis. These packs should include certificate treatment details and explain how supplied volumes match the industrial site’s consumption profile. They should also document what residual electricity was used where renewable supply did not cover demand.
CBAM-verifiable PPAs for industrial sites
A standard PPA may not be sufficient for CBAM-related needs where indirect emissions claims depend on verifiable evidence. A Serbia-based industrial PPA designed for CBAM purposes is expected to define the electricity source and delivery period along with metering points. It should also cover balancing responsibility and certificate cancellation.
The contract structure should address outages through treatment rules such as replacement power provisions and curtailment handling. It should also specify data access arrangements, verification rights and reporting formats required for downstream use in CBAM files. The strongest structure described involves a direct technical link between a renewable producer and an industrial site where traceability can be documented more clearly.
Even grid-based PPAs are described as potentially valuable if contractual terms, metering systems and certificate arrangements are robust enough. The evolution toward CBAM-verifiable PPAs is linked to supporting embedded-emissions calculations while reducing risk that EU buyers apply less favourable default assumptions. This ties PPA design directly to how claims may be substantiated.
Sectors highlighted for early attention in Serbia
The sectors identified for early attention include cement, fertilisers, steel and iron products, aluminium-related processing and hydrogen-linked future production. Chemicals and other energy-intensive manufacturing supplying EU customers are also included in the list of relevant industries. Cement and fertilisers are described as already central to indirect-emissions treatment in CBAM’s definitive architecture.
The DG TAXUD technical work referenced in the guidance also looks at potential extension of indirect-emissions coverage to additional sectors beyond those already central in the architecture. Even where indirect emissions are not yet fully chargeable for every sector, EU buyers may still request electricity evidence as part of supplier due diligence before long-term contracts are signed.
This means Serbian exporters need to build electricity evidence files ahead of time rather than waiting for final regulatory details on sector coverage. Large European customers are described as seeking auditable emissions data from Serbian suppliers during contract negotiations. The expectation is that evidence will be available before long-term supply arrangements are concluded.
Regional price volatility alongside carbon-evidence risk
Serbia’s power system remains exposed to regional volatility affecting day-ahead prices and generation patterns used in supply planning. In the Week 23 SEE electricity and gas market report referenced in the material, Serbia’s average day-ahead price fell 5.8% week on week to €99.63/MWh. Over the same period regional demand rose 8.2%, while variable renewable generation fell 8.9%.
The report cited shows Serbian hydro generation rising 30.8%, which helped soften local price pressure while the wider region relied more heavily on thermal dispatch and imports. The material notes that Serbia’s price can diverge from regional trends depending on domestic hydro availability, thermal availability and demand conditions aligning.
CBAM buyers are described as focusing on more than price when assessing electricity used in production processes sold into the EU. They ask what electricity was consumed, when it was consumed, what source it came from and which emissions factor applies under their assessment framework. This creates an additional layer of risk beyond SEEPEX price exposure tied to carbon-evidence requirements.
BESS integration into traceable renewable delivery
The material places battery storage within Serbia’s CBAM electricity strategy discussion alongside solar generation constraints tied to industrial load profiles. Solar output alone may not match production profiles of steel processors, cement plants, chemicals production sites, packaging operations, food processing facilities or logistics warehouses described in the text.
Batteries are described as shifting solar generation into more relevant consumption periods while reducing residual grid draw and improving delivery shapes of renewable PPAs. For Serbian renewable developers using BESS (battery energy storage systems), it is described as improving both merchant value and CBAM value by supporting evening delivery and reducing imbalance exposure.
For Serbian industrial buyers, storage-backed PPAs are presented as enabling better matching between production needs and green electricity consumption profiles used for traceability purposes. In a CBAM context as described here, storage is treated as part of traceability and delivery architecture for low-carbon industrial power rather than only an arbitrage asset.
A five-layer structure for CBAM-ready Serbian electricity products
A Serbian electricity producer or trader serving EU-facing industrial exporters is expected to prepare a standard product with five components: a commercial supply layer covering volume, price, tenor, shape, balancing and credit; a carbon-evidence layer covering generation source, metering, certificates, emission factor and residual supply; a verification layer covering data access, audit rights, monthly evidence files and third-party review; a production-allocation layer connecting consumption to product lines; and a risk-management layer covering outage replacement, curtailment handling, mismatch management, imbalance costs and default-factor exposure.
This structure is described as turning Serbian electricity supply into a market-access product aligned with how evidence may be used downstream in CBAM processes by EU importers or declarants inside their files.
Evidencing requirements requested by Serbian exporters from suppliers
The material describes expectations that Serbian exporters stop treating electricity as only a utility cost when selling into the EU market under CBAM-related scrutiny. Electricity procurement should follow similar discipline to customs documentation or product-origin evidence referenced in the text rather than being handled purely as a cost line item.
Exporters are expected to ask suppliers or traders for monthly metered supply records along with contract-source evidence and proof of certificate cancellation. They should also request settlement-period reconciliation details plus residual mix disclosure together with an explanation of whether the supplied electricity claim can support actual indirect-emissions reporting under DG TAXUD conditions referenced earlier.
The material also describes internal metering architecture needs at exporter level beyond plant-level bills of electricity usage alone. Exporters are expected to use production-line consumption data with allocation rules tied to process boundaries so that reconciliation between electricity use, production volumes and exported goods can be performed within their internal systems.
Market readiness through developing PPA offerings
The material describes Serbia’s potential advantage if market participants move early given existing industrial exporters, renewable pipelines, active traders and a developing PPA market serving EU-facing supply chains. A Serbian power producer offering CBAM-verifiable electricity is described as selling into a premium segment based on verifiability requirements rather than only pricing characteristics stated elsewhere in the text.
The same applies to traders able to manage green supply arrangements including balancing responsibilities tied to certificates plus evidence-file preparation capabilities described earlier in this material. Such traders would become strategic partners for exporters rather than only power suppliers within this compliance-oriented framework described here.
The future product description for industrial buyers is not limited to baseload or peakload categories or pricing index structures such as day-ahead indexed or fixed-price terms mentioned in the text. It is instead described using attributes including CBAM-ready, auditable metering records backed by certificates linked through PPAs with verifier-accessible evidence arrangements supporting downstream use inside CBAM files.
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