CBAM for Electricity Imports

Cross-border electricity into the EU is subject to CBAM based on the carbon intensity of the generating grid. Operators can use country defaults or demonstrate actual emission intensity with metered data.

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0.45tCO₂e / MWh (global default)
CN 2716HS code
MWhUnit for CBAM reporting

How electricity CBAM works

Unlike goods sectors, electricity CBAM has a unique two-path approach:

PathWhen to useEmission factor
Country default No metered generation data available; standard imports over the interconnector EU Commission default for exporting country's grid (updated periodically)
Actual metered data Electricity is linked to a specific generating unit via a PPA and metered hourly data is available Actual emission factor of the specific generator (can be near 0 for renewables)

Indicative country grid emission factors

CountryApprox. grid factor (tCO₂/MWh)Notes
Serbia~0.65Coal-heavy grid
Turkey~0.50Mixed coal/gas/hydro
Morocco~0.55Coal + growing renewables
Ukraine~0.40Nuclear + coal mix
Belarus~0.35Gas-heavy
Switzerland~0.025Hydro + nuclear; near exempt
Norway~0.018Near 100% hydro; EEA exempt

Values are indicative. Official default factors are published by the European Commission and updated annually.

Key CBAM rules for electricity

EEA countries are generally exempt

Norway, Iceland, and Liechtenstein participate in the EU ETS via the EEA agreement. Electricity imports from these countries are generally not subject to CBAM. Switzerland has a bilateral carbon link with the EU that may also provide exemption or deduction.

PPAs unlock the metered data pathway

If you have a Power Purchase Agreement tied to specific low-carbon generators (wind, solar, hydro) with hourly metered production data, you can demonstrate a near-zero emission factor. This can make a large commercial difference compared to the country default.

Interconnector operators bear reporting responsibility

For electricity, the authorised CBAM declarant is typically the licensed electricity importer or the transmission system operator handling the cross-border nomination. This differs from goods sectors where the customs importer is responsible.

Frequently asked questions

How does CBAM apply to electricity imports?

Electricity imports under CN 2716 into the EU are subject to CBAM based on the carbon intensity of the generating source. Importers use either the EU-published country default emission factor or actual metered data from a specific low-carbon generator. CBAM certificates must be surrendered annually equivalent to the embedded tCO₂ in the MWh imported.

What is the default emission factor for electricity?

It varies by country. The EU Commission publishes updated defaults — examples include Serbia (~0.65 tCO₂/MWh), Turkey (~0.50), Morocco (~0.55), Ukraine (~0.40). Hydro-dominated grids like Norway or Switzerland are close to zero.

Can renewable PPAs reduce my CBAM cost to zero?

Effectively yes, if you can demonstrate via metered data that the imported electricity came from a certified renewable generator with a verified near-zero emission factor. The PPA must be linked to a specific generating unit and hourly metered production data must be available for verification.

Who is responsible for CBAM compliance for electricity?

The authorised CBAM declarant — the licensed electricity importer registered in the EU CBAM Registry. In practice this is often the transmission system operator or a licensed energy trading company. Individual industrial buyers who purchase imported electricity domestically do not bear direct CBAM reporting obligations (the liability sits with the importer).

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Enter your MWh volume and grid emission factor to calculate your CBAM certificate exposure.

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