Imported electrical energy runs on its own track under CBAM. The default emission factor is the rule, not the fallback; there is no mark-up, no free-allocation relief and no 50-tonne exemption. This page gives the law as it stands, article by article.
Most of what is written about CBAM is written for steel, cement, aluminium, fertilisers and hydrogen. For electricity, a good deal of it is simply wrong. These are the rules that change, each with its article.
Electrical energy is listed in Annex II to Regulation (EU) 2023/956, and for goods in that annex only direct emissions are calculated and taken into account (Art. 7(1)). IR (EU) 2025/2547 Annex II point D.2 restates it for electricity.
Reg. (EU) 2023/956 Art. 7(1) and Annex II · IR (EU) 2025/2547 Annex II D.2
For electricity, where the goods are in scope, the order is fixed: the specific default value for the country of production; where there is none, the CO₂ emission factor of the EU; an alternative default only where a country has evidenced a lower factor to the Commission; and actual embedded emissions only where the cumulative criteria in point 5 of Annex IV are met.
IR (EU) 2025/2547 Annex II D.2 (a)–(d), D.2.1–D.2.4
The mark-up on default values applies to goods listed in Annex I other than electricity. The schedule that raises the other sectors’ default values by 10 % in 2026, 20 % in 2027 and 30 % from 2028 (1 % for fertilisers) does not touch electricity, and the act that publishes those values says so in its title.
Reg. (EU) 2023/956 Annex IV point 4.1 · IR (EU) 2026/1740 Annex I
The free allocation adjustment for electrical energy (CN 2716 00 00) shall be zero. The reason the act gives: no free allocation is made in respect of any electricity production, so there is nothing to adjust for. The free allocation adjustment that reduces the certificates due on the other goods does not exist here.
IR (EU) 2025/2620 Art. 1(2) and recital 11, reciting Directive 2003/87/EC Art. 10a(1)
The single mass-based threshold that exempts small importers shall not apply to imports of electricity or hydrogen. Any volume of imported electricity brings the obligation with it.
Reg. (EU) 2023/956 Art. 2a(4), inserted by Reg. (EU) 2025/2083
For other goods the reporting period is the year 2026 for anything imported in 2026, and for later years by default the calendar year of import, with the period of production used instead where there is sufficient evidence of it. For electricity there is no such branch: by derogation, the reporting period shall be the year of import.
IR (EU) 2025/2547 Art. 7(1) and 7(2)
Where electricity is produced in one third country and transits through other countries or Member States on its way in, the default values to be used are those of the country where the electricity was produced.
Reg. (EU) 2023/956 Annex IV point 4.2, second paragraph
Where embedded emissions are determined on the basis of default values, which is the normal case for electricity, a reduction for a carbon price paid may be claimed only by reference to yearly default carbon prices. As from 2027 the Commission may determine and publish yearly default carbon prices in the CBAM registry, for third countries where carbon pricing rules are in place.
Reg. (EU) 2023/956 Art. 9(4)
IR (EU) 2025/2621 Annex III publishes 18 CO₂ emission factors in tCO₂eq/MWh: one for each of 17 third countries and territories, and one for the European Union. A country that is not on the list, and is in scope, takes the EU factor.
IR (EU) 2025/2547 Annex II D.2(b) and D.2.2 · Reg. (EU) 2023/956 Annex IV point 4.2.2
The factors themselves are published in Annex III to Implementing Regulation (EU) 2025/2621, "Default values for electricity imported into the customs territory of the Union", on EUR-Lex.
The annex states that its data are based on data sourced from the International Energy Agency and that any further use or redistribution of the data is permitted for non-commercial purposes only, so we link to it rather than copy it.
Read Annex III on EUR-Lex →Every other country in scope: the EU factor.
Check scope first. Goods originating in Iceland, Liechtenstein, Norway or Switzerland, or in Büsingen, Heligoland, Livigno, Ceuta or Melilla, are outside CBAM altogether, so their electricity takes no row and no factor (Reg. (EU) 2023/956 Art. 2(4) and Annex III point 1). Origin here is the non-preferential origin referred to in Article 59 of Regulation (EU) No 952/2013, not the place of shipment (Art. 2(5)).
A country can get a lower factor than the one published: where it gives the Commission, by 30 June of the year, datasets from reliable alternative official sources showing its factor is lower, and the Commission considers them reliable, it amends the value, where feasible by 30 June of the following year (IR (EU) 2025/2547 Annex II D.2.3).
An authorised CBAM declarant may apply actual embedded emissions instead of default values only if every one of the following criteria is met, cumulatively. In practice this is a power purchase agreement route, with evidence required at every step.
Reg. (EU) 2023/956 Annex IV point 5 · evidence per IR (EU) 2025/2547 Annex II D.2.4
The electricity claimed is covered by a power purchase agreement between the authorised CBAM declarant and a producer of electricity located in a third country.
The producing installation is directly connected to the Union transmission system, or it can be demonstrated that at the time of export there was no physical network congestion at any point between the installation and that system.
The producing installation does not emit more than 550 grammes of CO₂ of fossil fuel origin per kilowatt-hour of electricity.
The electricity claimed has been firmly nominated to the allocated interconnection capacity by all responsible transmission system operators in the country of origin, the country of destination and, if relevant, each country of transit, and the nominated capacity and the production refer to the same period of time, not longer than one hour.
The fulfilment of the criteria is certified by an accredited verifier, who receives at least monthly interim reports demonstrating how they are fulfilled.
Where actual emissions are claimed, the producing operator prepares, for each authorised CBAM declarant that imported its electricity, a declarant-specific addendum to the Operator's Emissions Report: it confirms criteria (a) and (d), and where relevant (b), and states the quantity of electricity that declarant imported for which the criteria are met, with the evidence going to the verifier.
IR (EU) 2025/2547 Art. 8(4) and Annex IV point 1.1.1
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