What conditions must be met to declare actual embedded emissions for imported electricity under Carbon Border Adjustment Mechanism (CBAM)?

Four cumulative conditions: a power purchase agreement with a third-country producer; direct connection to the Union grid, or no physical congestion at export; no more than 550 grammes of fossil-origin carbon dioxide (CO2) per kilowatt hour (kWh); and firm nomination of capacity for the same period, no longer than one hour.

The four conditions

1. 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.
2. The producing installation is either directly connected to the Union transmission system, or it can be shown that at the time of export there was no physical network congestion at any point between the installation and the Union transmission system.
3. The installation does not emit more than 550 grammes of CO2 of fossil fuel origin per kWh of electricity.
4. 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. The nominated capacity and the plant's production refer to the same period of time, which shall not be longer than one hour.

Evidence and the pending change

• The Commission's Questions and Answers (Q&A) 6.12 say the criteria are cumulative. The evidence that must be submitted is laid down in Annex II, Section D.2.4 of Implementing Regulation (EU) 2025/2547.
• The Commission proposed on 17 December 2025 to modify these conditions in its CBAM amendment proposal. The Q&A says the proposal is under discussion and its outcome cannot be anticipated, and that until then the conditions must be complied with.

If the conditions are not met

• Our reading, implied by Q&A 6.10 and Annex IV(5) of the Regulation rather than stated in Q&A 6.12: if the conditions are not met, default values are used.
• The default values are carbon dioxide emission factors per country, region or group of countries, from International Energy Agency data covering a 5-year average, listed in Annex III to Implementing Regulation (EU) 2025/2621. If there is none for the country of production, the European Union (EU) factor applies (Q&A 6.10).
• Only direct CO2 emissions during production of the electricity are counted. Upstream emissions from making and installing wind turbines, for example, are not (Q&A 6.13).

What Senseible does here

Senseible does not trade or declare electricity and does not check capacity nominations. It reads fuel invoices and electricity bills into dated, fingerprinted installation records for an Indian plant.

• Electricity imports under CBAM (CN 2716)
• Western Balkans electricity exports
• PPA evidence for an actual grid factor
• Senseible for CBAM

Sources: European Commission, CBAM Questions and Answers, last updated 15 October 2026, questions 6.10, 6.12 and 6.13

Last reviewed 2026-11-05. The conditions may change if the December 2025 amendment proposal is adopted. Re-read Q&A 6.12 and Annex IV of the Regulation before relying on this.