Ukraine and Moldova synchronised to the ENTSO-E Continental Europe grid on 16 March 2022, bringing their commercial electricity exports to the EU within CBAM scope. Each flow is priced on the exporting country’s grid emission factor, or verified actual emissions under a direct-connection PPA, with the first surrender due 30 September 2027.
Both countries synchronised to the ENTSO-E Continental Europe grid on 16 March 2022, joining the frequency area that covers most EU member states. That connection turned regular commercial electricity exports to the EU into a physical reality, and because electricity is a covered CBAM group carrying no de-minimis, every cross-border flow sits in scope from the first unit. Both direct and indirect emissions are counted.
How the embedded emissions are set
Two bases exist, and only one applies to a given flow:
| Basis | When it applies |
|---|---|
| Exporting country’s grid factor | The default: a five-year average CO2 intensity, IEA-based, published per country in Implementing Regulation (EU) 2025/2621, Annex III |
| Verified actual emissions | Only where a power purchase agreement with a direct grid connection to the generator meets Article 7(3) and Annex IV of Regulation (EU) 2023/956 |
Actual generation emissions can sit below the grid default, but the data must be confirmed by a verifier accredited under Commission Delegated Regulation (EU) 2025/2551.
Timing and the routes out of scope
The obligations follow the general electricity rules:
- The first annual CBAM declaration and certificate surrender, covering 2026 imports, fall due on 30 September 2027.
- Synchronisation alone creates no exemption; free physical flow is not the test.
- Electricity from a third country whose market is coupled and integrated with the EU internal market can be exempt under Article 2(7), subject to anti-circumvention safeguards and a decarbonisation commitment.
GreenSutra’s consultants find synchronised-grid power is often assumed exempt because it moves freely, when synchronisation is exactly what brings it into scope. Only a market-coupling exemption under Article 2(7) removes the charge, and only verified actual emissions under a direct-connection PPA can lower it below the grid default. CBAM advisory covers declarant status, embedded-emissions calculation on the applicable grid factor, and certificate exposure for electricity in scope. The CBAM guide sets out the electricity treatment in full.
Sources: Regulation (EU) 2023/956 · Implementing Regulation (EU) 2025/2621 · European Commission CBAM