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National emission factors become a de facto electricity export tax

The definitive phase of CBAM has converted national electricity emission factors into a direct commercial charge on exports from the Western Balkans to the European Union. At current certificate prices, that charge is large enough to exceed the visible wholesale price spread on every major carbon-intensive export corridor.

The Q2 2026 CBAM certificate price was €75.28/tCO₂, almost unchanged from €75.36/tCO₂ in the first quarter. Short-term volatility declined, with daily auction values moving between €70.60 and €80.43/tCO₂, compared with a much wider first-quarter range.

Applied to national default values, the quarterly price produced implied costs of €86.42/MWh for Bosnia and Herzegovina€78.37/MWh for Serbia€74.08/MWh for Kosovo€73.70/MWh for Montenegro and €66.77/MWh for North Macedonia. Albania’s default value was zero, leaving its implied CBAM cost at €0/MWh.

The comparison with market prices is stark. Serbia’s average discount to Hungary was only around €12.9/MWh, far below the €78.37/MWh national-factor cost. Montenegro’s discount to Italy was about €27.2/MWh, compared with a default-factor charge close to €74/MWh. North Macedonia traded close to parity with Greece but carried an implied default cost of nearly €67/MWh.

These numbers mean that simple day-ahead arbitrage cannot support exports priced entirely under national default factors. Commercial transactions must instead rely on a combination of hourly price peaks, contractual positions, transit demand, expectations of regulatory reform or eligibility to use actual embedded-emission values.

The national approach creates a particularly severe distortion for renewable installations. A wind, hydro or solar plant in Serbia or Montenegro can have operational emissions close to zero, yet the electricity may be treated through a national factor dominated by lignite generation unless all conditions for actual values are met. The generator is therefore commercially represented by the carbon intensity of the wider system rather than its own plant.

Albania illustrates the opposite position. Its hydro-based system retained exports to Greece despite a spread of only €1.6/MWh. The zero default factor allowed Albanian electricity to remain competitive even when the conventional wholesale arbitrage was almost absent. North Macedonia, by contrast, saw exports to Greece fall 78%, while Greek exports in the opposite direction rose around 70%.

The emerging structure is a two-tier regional market. Low-carbon systems can preserve access to EU buyers at narrow spreads. Coal-intensive systems require exceptionally wide spreads, verifiable low-carbon supply or some other commercial driver.

The risk extends beyond existing trade. National emission factors influence the projected revenues of new renewable projects, the value of cross-border PPAs and the willingness of lenders to underwrite merchant exposure. A project whose base case assumes access to Hungarian or Italian pricing may face a material downgrade when that access depends on a verification framework that is not yet fully operational.

CBAM’s electricity provisions therefore operate much like a border tax on insufficiently documented origin. The charge is not determined only by the actual technology producing the power. It is determined by whether the contractual, metering and verification chain can prove that technology’s identity throughout the export process.

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