Eighteen numbers decide what imported electricity costs, and one rule covers every other country in scope

By Ahmed Medhat · Published18 September 2026

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 says where they are published, and then sets out the rule that covers everywhere else.

Where the eighteen factors are

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: seventeen countries and territories with a factor of their own, and the European Union. The figures are on EUR-Lex, in Annex III to Implementing Regulation (EU) 2025/2621 (https://eur-lex.europa.eu/eli/reg_impl/2025/2621/oj). We do not copy them here: 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.

The rule for every other country in scope

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 is in scope and does not appear in Annex III is not a gap. Its electricity is declared on the European Union row.

Scope comes before the factor

Before reaching for a factor, check that the Regulation applies. It does not apply to goods originating in Iceland, Liechtenstein, Norway or Switzerland, nor to goods originating in Büsingen, Heligoland, Livigno, Ceuta or Melilla (Regulation (EU) 2023/956 Art. 2(4) and Annex III point 1). Electricity originating in those places takes no row and no factor, because no CBAM obligation arises at all. Origin is settled by the rules for non-preferential origin referred to in Article 59 of Regulation (EU) No 952/2013 (Art. 2(5)), so the country a shipment is sent from does not decide it. Annex III also carries a point 2, reserved for third countries and territories outside the scope of the Regulation with regard to the importation of electricity specifically; it is an empty placeholder today, to be filled by the Commission under Art. 2(11). The Regulation also does not apply to electricity generated on the continental shelf or in the exclusive economic zone of a Member State, or of a country or territory listed in points 1 and 2 of Annex III (Art. 2(3a), point (a)). The exemption checker walks the origin test.

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 a row is 1 000 multiplied by that row's factor, in 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 links to the same annex.

The short version

Eighteen rows: seventeen countries and territories, and the European Union. Listed country of production: use its row. Not listed but in scope: use the European Union row. Outside the scope of the Regulation, which is Iceland, Liechtenstein, Norway, Switzerland and the five territories listed with them: no row at all. 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. 2(3a), Art. 2(4), Art. 2(5), Art. 2(11), Art. 7(3), Annex III points 1 and 2, 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.