CBAM by sector

CBAM and Electricity Imports

Electricity is one of the six sectors covered by the EU Carbon Border Adjustment Mechanism (CBAM). Like hydrogen, electricity has no 50-tonne de-minimis exemption: imported electricity is in scope at any volume. CBAM counts the direct emissions embedded in generating it. This page explains what is covered and what to do.

Electricity

Direct emissions · No exemption

TL;DR

  • Imported electricity is in scope under Regulation (EU) 2023/956, listed in Annex I.
  • There is no 50-tonne de-minimis exemption for electricity — it is covered at any volume.
  • Embedded emissions for electricity are counted as direct emissions from generation.
  • Because there is no threshold, electricity importers face authorisation, declaration and surrender obligations regardless of quantity.
Get the CBAM ChecklistDoes CBAM apply to me?

In scope

What CBAM covers for electricity

  • Electrical energy (imported electricity), as listed by its CN code in Annex I.

Electricity is measured in MWh rather than tonnes. Like hydrogen, it has no minimum volume below which you are exempt.

These products are listed in Annex I of Regulation (EU) 2023/956 by their CN code, so you confirm scope by matching your product code, not the product name alone. Use the goods & CN-code reference to check a specific code.

Emissions

How embedded emissions are counted

Emissions are counted as direct emissions. For electricity, CBAM counts the direct emissions from generation. The embedded emissions reflect the carbon intensity of the power feeding the interconnector — so the generation mix at the source matters. Regulation (EU) 2023/956

Actual, verified emissions data is preferred and usually cheaper than the conservative default values. Where you cannot get verified figures, you can fall back to the published default values, which carry a mark-up. See the CBAM default-values reference for the figures and mark-up rates.

The 50-tonne threshold

Does the de-minimis exemption apply?

No exemption: electricity is in scope at any volume

CRITICAL: electricity has NO 50-tonne exemption. Unlike steel, aluminium, cement and fertilisers, imported electricity is covered at any volume. The cumulative 50-tonne mass threshold (a mass measure) does not apply to electricity at all. 2025 Omnibus, Regulation (EU) 2025/2083

Use the scope checker to confirm your position.

The hard part

The hard part for electricity

  • No exemption: there is no minimum volume, so any electricity import brings full obligations.
  • Measured in MWh, not tonnes: the mass-based 50-tonne threshold simply does not map onto electricity.
  • Determining embedded emissions for power flowing across an interconnector, where the generation source can be hard to pin down.
  • Authorisation lead time: you must hold authorised CBAM declarant status before importing, and assessment can take up to 120 days.

What to do

What to do for electricity

  1. Recognise that imported electricity is in scope at any volume — there is no 50-tonne grace.
  2. Become an authorised CBAM declarant (or use an indirect customs representative who is) before importing; allow up to 120 days for the National Competent Authority’s assessment.
  3. Determine the embedded emissions of the imported electricity using actual data where available, or the published default values.
  4. File your annual CBAM declaration and surrender certificates by 30 September of the following year.

For the roles and how to apply, see the CBAM declarant guide; for when you need a verifier, see CBAM verification; and for collecting data from suppliers see the supplier data guide.

FAQ

Electricity and CBAM: common questions

Does the 50-tonne CBAM threshold apply to electricity?
No. Imported electricity has no de-minimis exemption. Unlike steel, aluminium, cement and fertilisers, electricity is covered at any volume under Regulation (EU) 2023/956, even after the 2025 Omnibus simplification.
How are emissions counted for imported electricity?
CBAM counts the direct emissions from generation. The embedded emissions reflect the carbon intensity of the electricity imported, with default values available where actual generation data cannot be established.
Do I need to register as a declarant to import electricity?
Yes. Because there is no volume threshold, importing electricity in the definitive period (from 1 January 2026) requires authorised CBAM declarant status. Apply via the CBAM Registry’s Authorisation Management Module and allow up to 120 days for assessment.
When is the first CBAM obligation for electricity due?
For 2026 electricity imports, the first annual declaration and certificate surrender is due 30 September 2027, the same as the other CBAM sectors.

Get ready for CBAM

Work through the CBAM Readiness Checklist, then explore the tools and guides built for your role.

Get the CBAM Checklist

This is guidance, not legal advice

This is guidance to help you understand how CBAM applies to electricity, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser. Some details remain subject to pending implementing acts; where the rules are unsettled we say so.

Sources

  1. [1]Regulation (EU) 2023/956, consolidated text including Annex I (EUR-Lex)retrieved 8 Jun 2026
  2. [2]European Commission (DG TAXUD): Carbon Border Adjustment Mechanismretrieved 8 Jun 2026
  3. [3]DG TAXUD: Simplifications for CBAM (Regulation (EU) 2025/2083)retrieved 8 Jun 2026
  4. [4]EUR-Lex: Carbon Border Adjustment Mechanism (summary)retrieved 8 Jun 2026

The CBAM Brief

Subscribe to The CBAM Brief

We watch Brussels so you don't have to. Plain-English CBAM updates, free.

No spam. Unsubscribe anytime.