Grid-intensity CBAM
for electricity exporters
Origin-grid carbon intensity declared per the live Annex III factor, validated against the XSD.
Reg (EU) 2023/956 · IR (EU) 2025/2621 Annex III · IR (EU) 2025/2620 · CN 2716 00 00
THREE EMISSION-FACTOR ROUTES — ANNEX III
Actual factors below the grid default are permitted only where the cumulative Annex III evidence is in place. Absent it, the declaration falls back to the origin-country grid emission factor. Electricity carries no free-allocation adjustment under Regulation (EU) 2025/2620 — the certificate obligation applies to the full phased-in fraction of gross embedded emissions.
THE PRODUCT IS THE ENERGY — CN 2716 00 00
Electrical energy enters CBAM under a single heading — CN 2716 00 00 — physically imported into the EU customs territory. Unlike steel, aluminium or cement, there is no production bill of materials and no precursor chain. The embedded emission is the generation itself, and the determining variable is the carbon intensity of the grid it came from.
Where actual data is unavailable, the default is the origin-country grid emission factor — a five-year average of yearly CO₂ intensity, IEA-sourced and weighted by fossil-fuel generation — under Annex III to Commission Implementing Regulation (EU) 2025/2621, applied via Article 7(3) of Regulation (EU) 2023/956. The published per-country factors live on the CBAM electricity data hub; this page does not restate volatile figures.
WORKED EXAMPLE — ORIGIN-GRID BASIS
Illustrative — the grid factor shown is a worked figure, not a regulatory value. The certificate price and phase-in fraction are read live from the platform; the actual origin-country grid factor is the published Annex III value for your country of origin, on the electricity data hub. Replace the grid factor with your origin value to size your own exposure.
WHAT THE XML MUST CONTAIN
INSTALLATION DATA
- Country of origin (grid)
- Emission-factor route (grid / PPA / direct link)
- Generating source where actual data applies
- Metering reference
- Reporting period
GOODS DATA
- CN code 2716 00 00
- Net electrical energy (MWh)
- Product designation — electrical energy
- Unit of measure (MWh)
- Point of grid coupling
EMISSIONS DATA
- Origin-grid emission factor (tCO₂/MWh)
- Default versus actual basis
- Embedded emissions (tCO₂)
- Evidence reference for actual claims
CARBON PRICE PAID
- Carbon price paid in country of origin
- Deduction amount
- Rebates applied
- Currency
INGESTION
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VALIDATION
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FAQ
Common questions from non-EU exporters.
How are CBAM emissions for imported electricity calculated — is there a per-product default like steel?
No. Electricity is not a manufactured good with a product-specific embedded-emissions figure. The product is the energy itself, and the emission is its generation, expressed in tCO₂ per MWh. Where actual data is unavailable, the default is the origin-country grid emission factor — a five-year average of yearly CO₂ intensity sourced from the IEA and weighted by fossil-fuel generation — under Annex III to Commission Implementing Regulation (EU) 2025/2621. The same imported MWh therefore carries very different embedded carbon depending on which national grid it came from.
When can I declare an actual emission factor below the grid default?
Only under narrow conditions. An actual factor is permitted where the electricity is supplied under a qualifying power purchase agreement with a renewable source, or through a direct technical link to a specific generating installation. Both routes require the cumulative Annex III evidence — assured contractual volume, metering at both the generation and import points, and no physical grid congestion between them. Without that evidence chain, the declaration falls back to the origin-country grid emission factor.
My EU importer is asking for an XML — what does Carbon Mandate actually produce?
Carbon Mandate prepares the CBAM XML on the origin-grid basis and validates it against the live DG TAXUD XSD schema before transmission. A PDF report or spreadsheet is not an accepted submission format. We are the preparer, not the filer: your EU importer submits the file to the EU Registry as the authorised CBAM declarant, and we are never the verifier. You receive a registry-ready file, not a communication template.
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