CBAM for electricity importers

Electricity is a CBAM sector, but it behaves differently from the material goods. Importers are typically electricity traders and utilities moving power across interconnectors, the emissions basis is different, and — importantly — there is no de minimis exemption. Every megawatt-hour imported is in scope.

Why electricity is in scope, and why it is different

Cross-border electricity carries the carbon intensity of the grid it came from, so it is included to prevent carbon leakage in power markets. Two features set it apart from steel, cement, or fertilisers:

• No 50-tonne threshold. The Omnibus simplification’s mass-based de minimis applies to cement, fertilisers, iron and steel, and aluminium — not to electricity. There is no small-importer exemption here.
• A different buyer. Electricity importers are usually energy traders and utilities rather than the small and mid-sized goods importers most CBAM guidance addresses, with the obligations sitting alongside existing energy-market and interconnector processes.

How emissions are determined

Because you cannot trace a specific electron to a specific power station, embedded emissions for imported electricity are generally established through default values unless the importer can demonstrate actual emissions under the prescribed methodology. That makes the evidence question less about chasing a producer for a figure and more about correctly applying the methodology and keeping the supporting records — contracts, volumes, metering and interconnector data, and any basis for using actual rather than default values.

What a clean electricity CBAM file looks like

Your first annual CBAM declaration covers 2026 imports and is due 30 September 2027 (full timeline). For electricity, the file centres on:

1. Import volumes by period, tied to metering and interconnector records.
2. Contracts and counterparties for the imported power.
3. The emissions basis used — default values, or actual emissions with the supporting methodology and evidence.
4. A traceable line from each declared figure back to its source records.

Kept properly, this is the evidence archive that supports the declaration and reduces penalty risk — and since there is no exemption, the discipline matters from the first import.

Where CarbonBorder Desk fits

Electricity importers are usually larger and more specialised than our typical clients, so the fit depends on how your obligations are already resourced. Where it helps, we provide the same operational layer: structuring import and emissions records, keeping the methodology basis documented, and maintaining a review-ready evidence archive. We are not a law firm, customs broker, energy adviser, or authorised declarant and we do not file declarations. If that fits your situation, a pilot diagnostic is the simplest way to test it.