Senseible

How does Carbon Border Adjustment Mechanism (CBAM) treat electricity in transit through a third country, or generated in a European Union (EU) Member State's Exclusive Economic Zone (EEZ)?

CBAM does not apply to electricity generated in the EEZ of EU Member States. Of three transit cases, only electricity made in third country C, routed via third country D and consumed in the EU is covered; if default values are used, the one for C. The other two are not.

Offshore generation in the EU's zone

The Commission's Questions and Answers (Q&A) 6.7 say electricity generated in the EEZ of EU Member States is not subject to CBAM. There is no obligation, for that electricity, to apply for authorised CBAM declarant status or to access the CBAM Registry.

Three transit cases (Q&A 6.11)

Why case 3 uses country C

Q&A 7.21 explains why: the country of production, the country of the last physical processing, is relevant for the default emission factor of imported electricity. Country of origin and country of production are usually the same, but they can differ.

Who declares

For electricity as for other CBAM goods, the declarant is the person who puts their CBAM account number in the customs declaration, the importer or its indirect customs representative. An importer established outside the EU must appoint an indirect representative (Q&A 6.8). Importers of electricity must always be authorised declarants, with no 50 tonne threshold (Q&A 1.1).

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.

Sources: European Commission, CBAM Questions and Answers, last updated 15 October 2026, questions 1.1, 6.7, 6.8, 6.11 and 7.21

Last reviewed 2026-11-05. Re-read Q&A 6.7, 6.8 and 6.11 after each Commission update.