Eighteen numbers decide what imported electricity costs, and one rule covers every country not on the list

By Ahmed MedhatPublished

Embedded emissions in imported electricity are determined by reference to default values, unless the authorised CBAM declarant demonstrates that the criteria for using actual emissions are met (Regulation (EU) 2023/956 Art. 7(3)). For most declarants the default value is therefore the figure that gets declared. Those default values are laid down in Annex III to Implementing Regulation (EU) 2025/2621 (Art. 1(4) of that act), and the annex is short: eighteen rows. This guide prints them, and then sets out the rule that covers everywhere else.

The eighteen factors, as the act prints them

Annex III is headed "Default values for electricity imported into the customs territory of the Union". It gives one emission factor per country or territory, in tCO2eq/MWh. The figures below are in the annex's own order, with a decimal point where the act prints a comma.

  • Albania: 0
  • Belarus: 0.383
  • Bosnia and Herzegovina: 1.148
  • Egypt: 0.442
  • Georgia: 0.440
  • Israel: 0.480
  • Kosovo: 0.984
  • Moldova, Republic of: 0.530
  • Montenegro: 0.979
  • Morocco: 0.907
  • North Macedonia: 0.887
  • Russian Federation: 0.585
  • Serbia: 1.041
  • Tunisia: 0.436
  • Türkiye: 0.718
  • Ukraine: 0.907
  • United Kingdom: 0.430
  • European Union: 0.612

That is seventeen countries and territories, and the European Union value. The highest factor on the list is Bosnia and Herzegovina at 1.148, followed by Serbia at 1.041; the lowest is Albania at 0. Eight of the seventeen sit above the EU value and nine sit below it.

The annex carries a licence notice of its own: the data are based on data sourced from the International Energy Agency under a Creative Commons non-commercial share-alike licence, and further use or redistribution is permitted for non-commercial purposes only. We print the figures as published in the act, with the act named as their source.

The rule for every country not on the list

The calculation act sets the order. The specific default value for the third country is used first; where no specific default value is available, the CO2 emission factor in the EU is used (Implementing Regulation (EU) 2025/2547 Annex II point D.2). Point D.2.2 says it in one line: "the CO2 emission factor for the Union shall apply". The basic regulation says the same thing: where a specific default value is not available, the alternative default value for electricity is set at the CO2 emission factor in the Union (Regulation (EU) 2023/956 Annex IV point 4.2.2).

So a country that does not appear in Annex III is not a gap. Its electricity is declared on the European Union row, 0.612.

Which country's factor: where the electricity was produced

Electricity often crosses more than one border. The basic regulation settles which row applies: where electricity is produced in a third country and transits through other third countries or Member States with the purpose of being imported into the Union, the default values to be used are those from the third country where the electricity was produced (Annex IV point 4.2). The factor follows the place of production, not the last border crossed.

What the factor is multiplied by

The calculation is one line. The emissions related to electricity are the electricity in MWh multiplied by the emission factor applied (Implementing Regulation (EU) 2025/2547 Annex II point D.1, Equation 35). For imported electricity only direct emissions are applicable (point D.2). On that equation, 1 000 MWh declared on the European Union row is 1 000 × 0.612 = 612 tonnes, and the same quantity on the Serbia row is 1 041 tonnes.

The annex prints a single factor per row. The recitals of the default values act describe a mark-up for default values for embedded emissions of goods other than electricity (recital 4); the electricity factors are instead described as the average of the yearly CO2 emission factors for the most recent five-year period for which reliable data is available (recital 8).

Two ways a factor can be replaced

A lower factor demonstrated by the country. Where a country, or group of third countries, submits sufficient evidence based on official and public information that its CO2 emission factor is lower than the specific default value or the EU value, and the conditions in point D.2.3 are fulfilled, an alternative default value is used (Annex II point D.2). This route belongs to the country, not to the declarant. The datasets go to the Commission by 30 June of a given year; where the Commission considers them reliable, it amends the relevant default values, where feasible by 30 June of the following year, and the modified values apply to electricity imported during the year in which the datasets were provided (point D.2.3). Datasets provided after 30 June move the timetable back: the amendment is due, where feasible, by 30 June of the second year following, and as a rule the modified values apply to electricity imported during the year after the datasets were provided (point D.2.3, second paragraph). The basic regulation carries the same possibility in Annex IV point 4.2.2.

Actual embedded emissions claimed by the declarant. An authorised CBAM declarant may apply actual embedded emissions instead of default values if the cumulative criteria of point 5 of Annex IV to Regulation (EU) 2023/956 are shown through the evidence listed in point D.2.4 (Annex II point D.2). We set those criteria out one at a time in the five conditions for using actual emissions on imported electricity.

How long these figures last

Implementing Regulation (EU) 2025/2621 applies from 1 January 2026 and is to be revised in 2027 at the latest (Art. 2). Its recital 11 adds that the default values and mark-ups are to be revised by December 2027 at the latest, and that the Commission should make all necessary efforts so that a revision can already be carried out in 2026. A factor read today should be read again against the act in force when the declaration is prepared. The electricity sector page prints the same factors from one data file that is checked against the act's text.

The short version

Eighteen rows: seventeen countries and territories, and the European Union at 0.612 tCO2eq/MWh. Listed country of production: use its row. Not listed: use the European Union row. Transit does not change the row. Two exits exist, one for a country that proves a lower factor to the Commission, one for a declarant who proves the five cumulative criteria for actual emissions.

Regulatory sources: Regulation (EU) 2023/956 Art. 7(3) and Annex IV points 4.2, 4.2.1, 4.2.2 and 5; Implementing Regulation (EU) 2025/2547 Annex II points D.1, D.2, D.2.2, D.2.3 and D.2.4; Implementing Regulation (EU) 2025/2621 Art. 1(4), Art. 2, recitals 4, 8 and 11, and Annex III.

This content is for informational purposes only and does not constitute legal or compliance advice. Contact DeCarbonPro for tailored guidance.

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