Sector reference

CBAM and the electricity sector

Current CBAM (Carbon Border Adjustment Mechanism) electricity defaults, actual-emissions route, accredited verification, and proposal-stage changes; not legal, tax, or customs advice.

Last updated: 2026-08-11 · Sources: Regulation (EU) 2023/956 (consolidated text) · Regulation (EU) 2025/2083 · Commission Implementing Regulation (EU) 2025/2621 · Commission Implementing Regulation (EU) 2025/2547 · Commission Implementing Regulation (EU) 2025/2546 · European Commission — CBAM legislation and guidance · European Commission proposal COM(2025)989 · EUR-Lex procedure 2025/0419(COD) — ongoing · EC DG TAXUD — Carbon Border Adjustment Mechanism · European Commission — CBAM sector resources

Who it matters for

EU importers of electrical energy — electricity traders and suppliers and the advisers supporting them.

Covered goods in this sector

The CN groups below are the electricity entries listed in Annex I of the consolidated regulation, drawn from the same reviewed dataset as the goods checker. Annex I mixes whole chapters, headings, and specific codes, so always confirm your exact 8-digit CN code with the goods checker.

• 2716 00 00Electrical energy

What to check first

• Confirm coverage: CBAM covers imported electrical energy as a single Annex I line, shown in the covered-goods list below.
• Note that the 50-tonne de-minimis threshold does not apply to electricity, so that exemption is not available for electricity imports (Article 2a(4)).
• Start from the current Article 7(3) rule: embedded emissions in imported electricity are determined by official default values unless the authorised CBAM declarant demonstrates that the criteria in point 5 of Annex IV for actual emissions are met.
• Treat actual emissions as an evidence and verification route, not as a supplier-number switch. Commission Implementing Regulation (EU) 2025/2547 specifies supporting information, and Article 8 requires declared actual emissions to be verified by an accredited verifier.
• Use Commission Implementing Regulation (EU) 2025/2621 as the legally binding source for definitive default values. The Commission workbook is provided for information purposes only.
• Keep COM(2025)989 separate: it proposes changes to the electricity emission-factor method and actual-emissions conditions, but the ongoing proposal has not been adopted.
• Use the linked default-value comparison only for its published non-electricity country worksheets; it does not calculate the electricity default or test the Annex IV actual-emissions criteria.

What makes electricity a distinct CBAM data journey?

Imported electrical energy is one of the six current CBAM sectors, but its emissions route, unit and threshold treatment differ from the mass-based goods journey. Start with the electricity-specific rules rather than reusing a steel, aluminium or cement workflow.

The current Annex I coverage is a single electrical-energy line. That narrow goods list does not make the preparation simple: the commercial contract, physical flow, producing installation, grid context, reporting period and emissions basis can sit in different systems and with different organisations. A workable record connects those pieces without treating a contract label or supplier claim as proof of the applicable emissions basis.

Electricity is excluded from the Article 2a de-minimis exemption. The mass-based threshold checker is therefore not the route for deciding whether a small electricity volume benefits from that exemption. Keep electricity out of a combined tonnes dashboard so an apparently low mass total does not create a misleading status.

Use the sector page as an orientation and the electricity default-values guide for the detailed current-rule explanation. Questions about a particular import, authorisation position or evidence route belong with the relevant National Competent Authority or a qualified adviser; the preparation record should preserve the question rather than turn it into a software conclusion.

• Keep electrical energy separate from mass-based goods in internal tracking.
• Record the importing entity, import period and quantity unit exactly as used in the underlying records.
• Link every emissions figure to its legal basis, source period and evidence status.

What is the current Article 7(3) default rule?

Current Article 7(3) of Regulation (EU) 2023/956 starts imported electricity from official default values under point 4.2 of Annex IV. Actual emissions are available only where the authorised CBAM declarant demonstrates that the criteria in point 5 of Annex IV are met.

This order matters. The current rule is not an open choice between any official default and any supplier number. A planning file can show both the default starting point and an actual-emissions evidence workstream, but it should not relabel the second as usable merely because it is available, lower, described as renewable or attached to a commercial agreement.

Create a basis field with controlled, descriptive states such as official default, actual route under review, actual evidence assembled, sent for qualified review and unresolved. Keep those workflow states distinct from a decision that the Annex IV criteria are met. A person reviewing the file should be able to see what is known, what source supports it and who owns the open question.

When a source or method changes, preserve the earlier version and its effective period. Do not silently overwrite the basis used for an earlier planning snapshot. Version history is especially important where current enacted rules and a proposal-stage methodology are being discussed at the same time.

• Default is the current starting point under Article 7(3).
• Actual emissions require the point 5 Annex IV criteria to be demonstrated.
• A favourable comparison does not establish which route applies.

How should the binding default source and workbook be separated?

Commission Implementing Regulation (EU) 2025/2621 is the legally binding source for definitive default values. The European Commission workbook is provided for information purposes only and should be treated as a navigation aid, not as a substitute legal source.

A good source record stores the act title, official reference, source URL, effective period, reviewed date and the exact row or provision being used. If a workbook view helps a team find a value, keep the workbook version and retrieval date as supporting metadata while retaining the implementing regulation as the authority for the legally binding value.

Do not fill an unavailable field with zero, copy a nearby country or product row, or infer an electricity factor from the non-electricity worksheets exposed by the CBAM Pulse comparison tool. That tool is intentionally bounded to reviewed country worksheets for goods other than electricity. It does not calculate an electricity default, identify the relevant electricity source entry or test the actual-emissions conditions.

Source status belongs next to the value, not in a remote methodology note. A reviewer should not have to remember whether a spreadsheet, web page, regulation or proposal carries legal force. Plain labels such as binding regulation, information-only workbook and proposal—not law reduce the risk of material from different layers being blended.

What does an actual-emissions evidence file need to connect?

Treat actual electricity emissions as an evidence route tied to a specific import and production context. The record should connect the producing installation, reporting period, contracted and imported quantity, technical and market evidence, emissions report, calculation basis and relevant flow or metering references.

Commission Implementing Regulation (EU) 2025/2547 specifies supporting information for the electricity actual-emissions conditions. Preparation starts by identifying which condition each item is intended to support. A file name or generic evidence tick is not enough: preserve who supplied the item, its date and version, the installation and period it covers, and the goods or import record to which it is linked.

Commercial and physical records may tell different parts of the story. Keep the agreement, nomination or scheduling context, border or interconnector information, delivery period, technical flow records and production information distinguishable. Do not infer that a contractual description establishes the physical or regulatory condition that a reviewer needs to assess.

Record missing or contradictory information openly. Useful gap states include installation not identified, period mismatch, quantity reconciliation open, calculation method unclear, source record not supplied, evidence outside the relevant period and qualified review required. Leaving a gap visible is safer than converting it into an assumption that looks like a fact.

• Identify the evidence owner and source organisation.
• Tie each document to an installation, period and quantity.
• Map each item to the condition it appears to support without declaring the condition satisfied.
• Keep revisions and superseded records available for review.

Where does accredited verification enter?

Where declared electricity emissions are based on actual emissions, Article 8 requires those declared actual emissions to be verified by an accredited verifier. Evidence collection, internal review and accredited verification are separate stages.

A supplier statement, power-purchase agreement, consultant note, sustainability certificate or completed checklist is not an accredited verification opinion. It may be relevant evidence, but its usefulness depends on its scope, period, method and connection to the producing installation and electricity flow. Preserve the document's actual status instead of promoting it to verified.

The verification work is performed by a verifier holding valid CBAM accreditation for the relevant activity scope when the report is issued. Accreditation is granted by a national accreditation body, not by the importer, supplier, Commission software or CBAM Pulse. A verification report is also not a certificate of the importer, the electricity product or the entire declaration.

Preparation can include identifying the expected review period, organising installation access questions, keeping the operator emissions report and source data together, and checking the verifier's stated scope and status through the appropriate official channels. Those steps support a later review; they do not ensure a satisfactory opinion or replace the verifier's risk-based work.

How should teams reconcile quantity, period and counterparties?

Build one traceable chain from the importer record to the electricity delivery and the evidence source. Reconcile quantities and periods without collapsing contractual, metered, scheduled and customs-facing records into one unlabeled number.

Start with a stable internal record identifier. Attach the importing legal entity, relevant declarant context, supplier and counterparty, border or delivery context, import period, quantity and unit, contract reference, invoice or settlement reference, and source-system owner. If systems use different time granularity, record the mapping rather than silently aggregating it.

Then link the emissions-basis record. For an official default, preserve the binding source and period. For an actual-emissions workstream, identify the producing installation and operator, the reporting period of the emissions data, the calculation record and every supporting evidence reference. Flag any mismatch between the delivery period and the emissions reporting period for review.

Use a reconciliation status that describes work, not legal effect: not started, records collected, difference identified, explanation requested, internally reviewed and referred for qualified review. Keep notes factual. For example, ‘supplier total differs from scheduled total; clarification requested’ is useful, while ‘accepted for CBAM’ would imply a conclusion outside the preparation tool.

How can procurement, trade, sustainability and finance divide the work?

Assign ownership by record and handoff rather than asking one team to ‘own CBAM’ in the abstract. Electricity preparation normally crosses commercial contracts, import records, technical data, emissions evidence and planning assumptions.

Procurement or trading can identify contracts, suppliers, counterparties and delivery periods. Trade or customs operations can maintain the importer, border and import-record context. Sustainability or technical teams can organise installation, method and emissions-report information. Finance can retain source-dated planning values and document how estimates were assembled without treating them as final obligations.

Name one coordinator to maintain the shared record and gap log. The coordinator does not become the legal decision-maker or verifier; the role is to ensure that requests have owners, responses are attached to the right record, source versions remain visible and unresolved questions reach the appropriate external or internal reviewer.

A strong handoff includes the record identifier, requested item, reason for the request, installation or period scope, due date, recipient, current evidence link and next review point. Avoid email-only ownership. When a person changes role or a contract closes, the open question should remain visible to the team.

• Commercial owner: contract, counterparty and delivery context.
• Trade owner: importer and import-record context.
• Technical or sustainability owner: installation, method and evidence context.
• Finance owner: source-dated planning assumptions and reconciliations.
• Coordinator: gap log, handoffs, version history and escalation route.

How should COM(2025)989 be tracked?

COM(2025)989 proposes changes to the electricity emission-factor method and actual-emissions conditions, but it is a proposal—not law. It must stay separate from current calculations, current-rule explanations and present evidence decisions unless adopted text enters into force.

Maintain a regulatory watch item with the proposal identifier, procedure link, last reviewed date and plain status. Do not copy proposed methodology into a current assumptions field. Do not describe a proposed application date as if it were already an enacted obligation. If the procedure advances, compare the final adopted wording, effective dates and implementing details before changing current content or calculations.

The proposal may be useful for scenario awareness: teams can note which records or data fields could become relevant if the final law changes. Keep that work clearly labelled as horizon scanning. A scenario column should never overwrite the current basis or appear in an export without its proposal status.

Avoid unsupported product counts, simplified political summaries or secondary-source figures. The official proposal and procedure record are the sources of record for status. Where the official procedure remains ongoing, the correct public label remains proposal—not law.

What does a useful monthly electricity review look like?

A monthly review keeps import records, evidence requests, source status and proposal monitoring aligned. It is a preparation control, not a filing or verification process.

Reconcile new electricity import or delivery records to the internal register. Check that quantity, unit, importer, period and counterparty fields are populated. Review the current emissions basis for each line and confirm that the official source version or actual-evidence workstream remains attached. Carry differences into the gap log rather than fixing them with undocumented assumptions.

Review supplier and operator requests by age and impact. Ask whether the installation, reporting period, method and evidence scope are clear, not merely whether a document was received. If actual emissions are being considered, keep accredited-verifier engagement and open criteria questions visible as distinct work items.

Finally, check official sources for adopted changes and keep proposal monitoring separate. Record the review date even when nothing changes. That negative evidence helps explain why a planning record continued to use the same source version and prevents a later team from assuming the topic was forgotten.

Electricity CBAM questions