CBAM for electricity and hydrogen
Electricity and hydrogen are the two CBAM sectors without a mass threshold. Anyone importing them into the EU needs authorised CBAM declarant status from the first import – in practice this mainly affects energy traders and large buyers.
At a glance
- No 50-tonne threshold: authorised CBAM declarant status from the first import.
- Electricity and hydrogen do not count towards the threshold of other CBAM goods either.
- Only direct emissions count.
- Mark-up on default values: none for electricity, hydrogen 10% (2026), 20% (2027), 30% from 2028.
Which goods are affected?
Electrical energy (CN 2716 00 00) and hydrogen (CN 2804 10 00). The 50-tonne exemption does not apply to either: the very first import requires authorised CBAM declarant status.
| CN code | Goods | Sector |
|---|---|---|
| 2716 00 00 | Electrical energy | Electricity |
| 2804 10 00 | Hydrogen | Hydrogen |
Electricity specifics
Electricity has its own default values per country of origin and its own rules under which actual emissions may be used. No mark-up is added to default values for electricity, and there is no free allocation adjustment for electricity – every tonne of embedded emissions is one certificate.
Electricity is usually imported by energy traders and grid operators. For them CBAM is part of electricity trading; CBAMfix focuses on the mass threshold for goods and does not calculate electricity.
Hydrogen specifics
For hydrogen only the direct emissions of production count. The same mark-up as for steel and aluminium is added to default values. Unlike electricity, the free allocation adjustment is deducted.
The CBAM declaration for imports in 2026 must be submitted by 30 September 2027; the certificates must also be surrendered by then. Certificates are sold from 1 February 2027 on the common central platform. From 2027, at the end of each quarter at least 50% of the embedded emissions imported since the start of the year must be covered by certificates.
How CBAMfix handles it
If a customer records electricity or hydrogen, CBAMfix immediately points out that authorisation is required regardless of quantity – and does not count these items towards the 50-tonne threshold of other goods.
Frequently asked questions
Does the 50-tonne threshold apply to hydrogen?
No. For hydrogen and electricity, authorised CBAM declarant status is required from the first import.
Does imported hydrogen count towards the threshold for my other goods?
No. Electricity and hydrogen are not counted towards the 50-tonne threshold, but are always subject to CBAM obligations themselves.
Which emissions count for electricity?
Only direct emissions. Electricity has its own default values without mark-up, and there is no deduction for free allocation.
Stay on top of the 50-tonne threshold
CBAMfix reads your import documents, checks every CN code against Annex I, keeps count and warns you in time before the authorisation deadline.
Try free for 14 daysMore topics
- Am I subject to CBAM?
- CBAM deadlines 2026 and 2027
- The CBAM annual declaration for 2026
- Which documents do I need for CBAM?
- CBAM for DDP deliveries and importers outside the EU
- The CBAM 50-tonne mass threshold
- Becoming an authorised CBAM declarant
- CBAM for customs agencies and forwarders
- CBAM certificates: price, purchase and surrender
- CBAM for iron and steel
- CBAM for aluminium
- CBAM for cement and clinker
- CBAM for fertilisers
Legal status as of 11 October 2026. Based on Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 and the related implementing acts. CBAMfix does not replace legal, tax or customs advice; the Regulation and the guidance of the competent authority are authoritative.