The most CBAM-exposed electricity exporters are the coal-heavy grids of the Western Balkans, where a higher-carbon grid emission factor raises embedded emissions. Hydro-rich Albania has a default factor of zero. Norway and Switzerland are electrically connected to the EU but stay outside scope under Annex III, and Great Britain’s grid is decarbonising yet remains in scope.
The coal-heavy grids of the Western Balkans face the largest CBAM charge. The embedded emissions of imported power default to the exporting country’s grid CO2 emission factor, not to any single generator. That factor is a five-year average published per country in Implementing Regulation (EU) 2025/2621, Annex III, so a coal-dominated fuel mix yields a high figure and a hydro or nuclear-heavy mix a low one. Within the same region, hydro-rich Albania has a default factor of zero.
CBAM position by exporting grid
| Exporting grid | CBAM position |
|---|---|
| Coal-heavy Western Balkans (Bosnia and Herzegovina, Serbia, Kosovo, Montenegro) | Highest default factors, 0.98 to 1.15 tCO2eq per MWh |
| Hydro-rich Albania | Default factor of zero |
| Norway and Switzerland | Connected but outside CBAM scope under Regulation (EU) 2023/956 |
| Great Britain | Decarbonising, still in scope |
| Ukraine and Moldova | Synchronised to ENTSO-E on 16 March 2022, now in scope |
Norway sits inside the EU emissions-trading system and Switzerland is linked to it, so neither country’s grid mix changes its position. Great Britain’s grid is decarbonising, yet its power exports to the EU stay in scope. Ukraine and Moldova joined the ENTSO-E Continental Europe grid on 16 March 2022. Both are listed in Annex III of Implementing Regulation (EU) 2025/2621, so their electricity exports are in scope.
Default factor versus verified actual data
The default grid factor is the starting point. Actual generation emissions may replace it only where the power purchase agreement and the installation meet every criterion in Article 7(3) and Annex IV, point 5. An independent verifier accredited under Commission Delegated Regulation (EU) 2025/2551 certifies that. A market-coupling exemption under Article 2(7) can remove an integrated third-country market from CBAM entirely, subject to anti-circumvention and decarbonisation conditions. Electricity carries no de-minimis, so every cross-border flow counts from the first unit, and only direct emissions are included.
GreenSutra’s consultants note that proximity to the EU grants no relief by itself; only exclusion under the base CBAM Regulation, the market-coupling route or a genuinely low grid factor changes the position. The CBAM advisory covers declarant status, embedded-emissions calculation and certificate costs, and the CBAM guide sets out the default-versus-actual mechanism in full.
Sources: Regulation (EU) 2023/956 · Implementing Regulation (EU) 2025/2621 · European Commission CBAM