Proposed EU CBAM revisions for electricity exporters
Bosnia and Herzegovina could lower the carbon cost applied to electricity exports to the European Union after several proposals were incorporated into draft revisions of the EU Carbon Border Adjustment Mechanism. The Ministry of Foreign Trade and Economic Relations said the changes have been forwarded to the European Parliament and the Council for consideration. The proposals aim to reduce the risk that exporters using carbon-intensive but mixed-generation systems are assessed using default values that do not reflect renewable and lower-carbon output.
One amendment would calculate the carbon content of exported electricity based on the exporting country’s actual generation mix, including hydropower, wind and solar. A second proposal would simplify verification requirements and recognise electricity delivered under power purchase agreements. This includes cases where contracts are arranged through intermediaries.
Financial impact for Bosnia’s coal and hydropower mix
The Ministry said the distinction is financially material for Bosnia and Herzegovina. The country remains dependent on coal-fired generation, while also operating a substantial hydropower fleet. It said methodologies relying only on conservative default factors can overstate emissions linked to specific export transactions. That outcome could weaken the commercial value of renewable electricity supplied for export.
The draft revisions would also apply the revised CBAM treatment retrospectively from 1 January. The Ministry said this could address costs incurred since the start of the definitive CBAM phase. It estimated that combining revised EU rules with a domestic methodology could reduce the annual burden on Bosnian electricity exports by as much as €13 million.
Evidence requirements and domestic emission factor methodology
The Ministry said any potential saving would depend on evidence rather than on the national generation mix alone. Exporters would need metering records, dispatch data, contractual matching, and verifiable information showing the origin and emissions intensity of supplied electricity. For power purchase agreements, greater value would apply only where contracted generation can be traced through scheduling, nomination, settlement, and meter data.
The Ministry has prepared a methodology for calculating the carbon dioxide emission factor for Bosnia and Herzegovina’s electricity system. It described this as an essential step, but said a national factor cannot replace plant-level and transaction-level monitoring when exporters seek preferential treatment for renewable or lower-carbon electricity. The proposals are intended to support credible renewable export products from hydropower producers and suppliers able to structure such offerings.
Status of legislative process and verification standards
The legislative process is not complete. The draft must still pass through the European Parliament and the Council before final adoption. The Ministry said final commercial benefit will depend on detailed implementing rules and on the standard of verification evidence accepted by EU authorities. Coal-based electricity would remain exposed to carbon costs as EU importers strengthen due diligence around embedded-emissions declarations.
