Hungary and Romania together reported nearly 7 TWh of electricity imports attributed to Serbia in 2025, according to EU customs statistics, making them the largest of four EU markets in the data. The gross totals do not establish which Serbian power plants generated the electricity for emissions accounting under the EU Carbon Border Adjustment Mechanism (CBAM).
The statistics recorded 9.845 TWh of imports attributed to Serbia, valued at approximately €1.15 billion, equivalent to $1.30 billion at the 2025 average euro-dollar exchange rate. Hungary reported 3.636 TWh worth approximately €427.8 million, while Romania recorded 3.131 TWh valued at approximately €381.8 million. Bulgaria reported 1.625 TWh worth approximately €190.4 million, and Croatia 1.254 TWh valued at approximately €130.1 million.
These are gross reported trade flows and border attributions, not measures of Serbia’s net domestic electricity exports or independently verified generation. Electricity can be scheduled across several borders and traded more than once, so attribution to Serbia at a border does not show that a specific Serbian generating unit supplied the imported megawatt-hours.
Customs data do not verify emissions origin
For CBAM purposes, the customs origin in trade statistics is not the same as a verified identity for the installation that generated the electricity. The mechanism covers electricity under CN 2716 00 00, while the cited trade data use HS271600. The importer exemption for consignments below 50 tonnes does not apply to electricity.
The importing declarant must account for embedded emissions from imported electricity. For imports into Hungary and Romania, the formal obligation rests with the authorised EU declarant, which may be an electricity trader, supplier or another eligible importing entity. Industrial electricity users may face higher prices indirectly through supply contracts, but that does not make them the customs declarant.
Using actual electricity emissions instead of prescribed defaults is subject to strict regulatory conditions. A standard renewable power purchase agreement or a guarantee of origin alone does not establish that all conditions for actual-emissions treatment have been met.
Tracing an imported megawatt-hour to a generating installation requires matched generation-meter records, dispatch schedules, evidence of the contractual chain and nomination records. Public cross-border statistics also cannot identify the steelworks, chemical plant, factory or data centre that ultimately consumes the electricity; that requires supply and settlement data.
CBAM exposure depends on trade and rule assumptions
Serbia’s Ministry of Finance modeled electricity-related CBAM exposure at €21.8 million in 2026 under a baseline scenario, while warning that already-weaker trade flows could make the actual effect lower. It separately estimated €20.7 million under a scenario excluding transit effects, and around €14.5 million if proposed rules on the national generation mix were adopted.
The three estimates reflect separate assumptions, not cumulative costs or a regulatory concession already in force. The figures therefore do not establish a guaranteed charge or exemption.
Electricity import economics respond to hourly market prices and congestion. An additional carbon charge can widen the minimum price difference needed to justify imports from a non-EU border, particularly during hours when EU renewable generation is abundant. A trading portfolio that appears profitable before CBAM and transmission charges may become marginal when default-emissions exposure is applied.
A proposed practical remedy is an auditable evidence chain linking each imported volume and its EU declarant to the generating installation, metering, dispatch and cross-border schedule. For Serbian exporters and EU buyers, documentary capability may be as important to maintaining competitiveness as transmission capacity or wholesale electricity prices.
Elevated by CBAM.Clarion Engineer
