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Electricity

Imported electricity under CBAM: scope, default factors by originating jurisdiction, coupled vs uncoupled markets and the actual-emissions exception.

By Lakshmikumaran and Sridharan attorneysReviewed by LKS CBAM editorial team
Last reviewed: June 2026
On this page
  1. Direct answer
  2. What is covered
  3. Default emission factor by originating jurisdiction
  4. Coupled vs uncoupled markets
  5. Claiming actual emissions for imported power
  6. Electricity embedded in other goods
  7. FAQ
  8. What to read next

Direct answer

Imported electricity is in CBAM scope at CN 2716 00 00. Because the physical source of electrons on a synchronised grid cannot be traced, the methodology relies on a default emission factor based on the originating third country's power mix, unless the declarant qualifies for the narrow exception that allows actual emissions to be claimed for a specific power purchase agreement and transmission path.

What is covered

Electricity is a single line in Annex I: CN 2716 00 00. The in-scope event is import into the EU customs territory across an interconnector from a third country. Intra-EU power flows are outside CBAM; they remain priced under the EU ETS at the generator level.

1 CN code in 1 sub-group (Annex I, DG TAXUD)
Electricity1
2716Electrical energy1
2716 00Electrical energy1

Electricity: process schematic

Sources

Default values track the fuel mix and grid emission factor of the country of origin.

Implementing Regulation (EU) 2023/1773, Annex IV (electricity)

Default emission factor by originating jurisdiction

The default emission factor is set per third country based on the CO2 intensity of the country's power mix. For countries whose grid is coupled with the internal electricity market and is not net-exporting fossil generation, the EU average is used. For uncoupled grids and net-exporting jurisdictions, a country-specific factor applies. The values are published as part of the default-values dataset.

Loading default values dataset...

Coupled vs uncoupled markets

Annex IV distinguishes electricity flows from a third country whose wholesale market is coupled to the EU internal market (single day-ahead coupling, balancing) from flows from uncoupled jurisdictions. Coupled flows are treated as if they were intra-EU for default-factor purposes; uncoupled flows attract the third country's specific factor. The classification is set by the Commission, not by the declarant.

Claiming actual emissions for imported power

A declarant may use the actual emissions of a specific generator instead of the default factor only if all of the following hold: there is a direct power purchase agreement with that generator; nominated transmission capacity on the interconnector is held for the contract period; the generator is registered in the relevant transmission system operator's schedule; and emissions are measured and verified to the installation methodology. Otherwise the default factor applies.

Electricity embedded in other goods

Embedded electricity in manufactured CBAM goods (aluminium, steel, hydrogen, fertilisers) is reported separately as the indirect emissions component of those goods, not as imported electricity under CN 2716. The two flows do not double-count: the cross-border power import line covers only electricity imported as a commodity.

Frequently asked questions

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What to read next

Source: Navigating CBAM by Lakshmikumaran and Sridharan Attorneys. Canonical: https://cbam.lkslaw.com/sectors/electricity (ref 0peg411). Reuse permitted under the site terms with attribution and a link back.

Discuss this topic with our international trade and customs practice: write to ankur.sharma@lakshmisri.com.