CBAM covers imported electricity under combined-nomenclature code CN 2716, one of six covered product groups. Unlike cement or steel, electricity has no 50-tonne exemption, so imports from countries outside the Annex III list enter scope from the first unit. By default they are priced on the producing country’s carbon emission factor.
Imported electricity is one of the six product groups the Carbon Border Adjustment Mechanism covers, and it behaves unlike the material goods in two ways that matter at once. There is no de-minimis allowance. The 50-tonne threshold per importer per calendar year, counted across all CBAM goods, does not apply to electricity. Imports from countries outside the Annex III list therefore count from the first unit. By default the embedded emissions come from the CO2 emission factor of the country where the electricity was produced. Data from a single installation counts only if the Annex IV point 5 conditions are met.
How the obligation is measured and when it falls due
The calculation and the deadlines follow the same regime that governs the other CBAM goods, with electricity-specific rules on the emission basis.
- Electricity is the power product itself, so its embedded emissions are those of generating it rather than an indirect addition from purchased power.
- The default is the CO2 emission factor of the country where the electricity was produced, listed in Annex III to Implementing Regulation (EU) 2025/2621. Where no country value is listed, the EU factor applies. Actual emissions can replace it only under a power purchase agreement that meets the Annex IV point 5 conditions.
- The first annual declaration and certificate surrender, covering 2026 imports, is due 30 September 2027.
- The free allocation adjustment for electricity is zero, because EU power producers receive no free allocation. Certificates therefore cover all the embedded emissions from 2026, less any carbon price deduction.
Which parties actually carry it
The obligation reaches parties with a physical link to the EU grid, not distant producers without one. The obligation sits with the authorised CBAM declarant, meaning the importer or its indirect customs representative. Where transmission capacity is allocated explicitly, the person who nominates it is treated as the declarant. A business outside the EU that does not export electricity meets CBAM electricity only as a comparison against goods such as steel or cement that it does ship. CBAM compliance support covers declarant status, embedded-emissions calculation and certificate exposure. A CBAM guide sets out the covered groups and the compliance timeline.
Sources: Regulation (EU) 2023/956 · Implementing Regulation (EU) 2025/2621 · European Commission CBAM