The electrical percolation of alternating current through two-phase polyethylene/graphite composite electrodes with different contents of graphite microparticles immersed in aqueous KCl solutions has been studied. Above the graphite content of the first percolation threshold, the electrochemical impedance response of this electrode is associated with an equivalent circuit of resistance Ru in series with a constant phase element (CPE). An insulator material + conducting filler model is proposed in which the electroactive surface is considered as the intersection of the percolation cluster through the solid and the cluster associated with the interfacial region. CPE is analyzed assuming a distribution of microcapacitors of the graphite particles in contact with the dielectric solution and inside the dielectric polymeric phase.