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Embedded emission reporting for electricity exported to the EU via interconnection: default values, or actual emissions where the conditions are met.
The EU CBAM mandates declaring the embedded emissions of electricity imported into the EU (CN 2716 00 00). The declaration obligation sits with the Authorised CBAM Declarant in the EU; producers and suppliers selling electricity from Türkiye via the Bulgarian and Greek interconnections provide the data. CarbonEmit compares the country default value with the actual-emission option, together with its conditions.
Electricity is calculated differently from other CBAM goods: quantities are declared in MWh rather than tonnes, and default values are based on the CO₂ emission factor of fossil-fuel electricity generation in the country of production. The 2025 amendment (Regulation (EU) 2025/2083) added electricity to Annex II (direct emissions only), and the 50-tonne de minimis exemption does not apply to electricity.
The product codes below fall under the EU Carbon Border Adjustment Mechanism (CBAM) and need embedded emission data for the EU importer’s declaration.
Official source: European Commission CBAM Regulation (EU 2023/956 Annex I)
CarbonEmit provides sector-specific emission factors, automatic CN code mapping and CBAM XML/Excel output aligned with the EU CBAM Registry process.
CN 2716 00 00 (electrical energy) is CBAM-covered. Electricity is an Annex I good; every MWh imported into the EU requires an embedded emission declaration.
Default values are based on the CO₂ emission factor the Commission sets for the country of production. Actual emissions can only be used if all conditions in Annex IV point 5 of the Regulation are met: a PPA between the declarant and the producer; the installation is directly connected to the EU transmission system or there was no physical network congestion; the installation emits no more than 550 g of fossil CO₂ per kWh; the electricity is firmly nominated to allocated interconnection capacity by all responsible transmission system operators (matched over no more than one hour); and an accredited verifier certifies this. CarbonEmit calculates both options.
Guarantees of origin such as YEK-G or I-REC are not enough on their own to declare actual emissions. You also need a PPA, hourly matching through firm nomination and certification of the other Annex IV conditions by an accredited verifier. CarbonEmit collects the PPA, nomination records and generation data in one audit file.
Türkiye's transmission grid is connected to the European grid via Bulgaria and Greece, with trade in both directions. The CBAM declaration is based on the quantity of electricity (MWh) imported into the EU.
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