CBAM sets imported-electricity emissions from the exporting country’s grid CO2 emission factor, a five-year average published per country in Implementing Regulation (EU) 2025/2621, Annex III. Actual generation emissions apply only where a power purchase agreement with a direct grid connection meets Article 7(3) and Annex IV, point 5 of Regulation (EU) 2023/956.
Under CBAM, imported electricity is not measured at a single installation the way steel or cement can be. The default embedded-emission value is the exporting country’s grid CO2 emission factor, a five-year average based on best available data and published for each country in Implementing Regulation (EU) 2025/2621, Annex III. As a per-country figure it has no EU-wide equivalent, so the value that governs any consignment is the one listed for its country of origin. Electricity carries no de-minimis threshold and counts both direct and indirect emissions, so every cross-border flow falls in scope.
Default versus verified actual
| Basis | When it applies | Effect |
|---|---|---|
| Grid emission factor default | The general case | Country-of-origin grid factor, published per country |
| Actual generation emissions | Qualifying direct-connection PPA | Can sit below the country default |
When actual emissions can be used
Actual generation data may replace the default, but only under narrow conditions:
- A power purchase agreement with a direct grid connection to the generator must satisfy Article 7(3) and Annex IV, point 5 of Regulation (EU) 2023/956.
- Generation from a low-carbon source can then be declared below the country default.
- The data must be verified by a verifier accredited under Commission Delegated Regulation (EU) 2025/2551, an independent step separate from any advisory work.
GreenSutra’s consultants note that electricity traders often expect a plant-level figure, when in practice the country grid factor governs unless a qualifying direct-connection PPA is in place. CBAM compliance support covers declarant status, embedded-emissions calculation and certificate-cost planning for electricity flows.
The CBAM cost calculator converts an emission factor into an estimated charge by volume and import year.
Sources: Regulation (EU) 2023/956 · Implementing Regulation (EU) 2025/2621 · Commission Delegated Regulation (EU) 2025/2551