Serbia’s Finance Ministry estimates potential CBAM exposure for Serbian exports in 2026 at EUR 140.2 million. The figure relates to EU imports of iron and steel, aluminium, electricity, fertilisers and cement. The ministry said the scenario is indicative rather than a fixed liability.
Under the EU framework, the importer or an eligible indirect customs representative must handle emissions declarations and surrender the required CBAM certificates. The ministry noted that Serbian suppliers could still bear part of the cost through contract pricing or lower sale prices.
Indicative 2026 exposure by product category
The ministry’s indicative calculation uses 2025 export volumes, default emissions factors and a carbon reference price of EUR 75.36 per tonne. It assigns EUR 89.1 million to iron and steel, EUR 19.5 million to aluminium and EUR 21.8 million to electricity. Fertilisers are allocated EUR 7.8 million, while cement accounts for EUR 1.9 million.
The ministry described these allocations as scenario outputs rather than commitments that automatically translate into payments. It also stated that the eventual burden depends on how emissions are reported and how certificate requirements are determined under EU rules.
How CBAM costs can be shared in contracts and supply chains
The ministry said contract terms shape how costs are shared between buyers and Serbian producers. Where a buyer has strong negotiating power or can switch to alternative European supply, a Serbian producer may face a lower net ex-works price. It added that the party named on the customs declaration does not necessarily determine who ultimately bears the charge.
The ministry also described how charges can move across multiple stages of a supply chain. It said they may be spread across product grades or recovered through wholesale trading margins and bilateral supply contracts.
A Polish steel service centre, for example, could pass a charge to a metal fabricator supplying a German machine maker. An aluminium distributor could spread costs across grades, while a power importer could recover them through a trading margin or bilateral deal.
Compliance requirements for importers and data use
Within the EU CBAM framework, an importer or eligible indirect customs representative must obtain authorisation, report embedded emissions and surrender the required certificates. Importers may seek emissions data supported by verification to avoid reliance on costly default values. The ministry also noted that some or all of the expected charge may be passed to suppliers under contract terms or included in resale prices.
For large buyers of steel and aluminium, practical issues include emissions pricing, facility verification, contractual indemnities and financing certificate purchases. The ministry said producers with verifiably lower emissions or specialist specifications may be better positioned to defend margins, while commodity sellers facing intense competition may be pushed to absorb costs.
It added that consumers could face higher prices even without any direct CBAM registration obligation.
Certificate prices and reporting timeline in 2026
The published EU CBAM certificate price was EUR 82.32 per tonne in the third quarter of 2026, compared with EUR 75.36 per tonne in the first quarter. The ministry said that because certificate prices can change, using a static assumption may not match the eventual bill.
The ministry also stated that multiplying the full carbon price by every tonne of gross emissions is not a substitute for the legal calculation under CBAM. It said the calculation depends on product emissions, EU free-allocation adjustments and eligible carbon prices paid in the producing country.
Serbia’s carbon tax impact and key thresholds
Serbia introduced a greenhouse-gas emissions tax in January 2026 at a stated headline rate of EUR 4 per tonne of CO2-equivalent. In a modeled scenario, potential 2026 exposure falls from EUR 140.2 million to EUR 127.3 million if the EU fully recognises domestic carbon pricing.
The ministry said this recognition is an assumption rather than a legal guarantee. It noted that an importer would need evidence of the qualifying carbon price actually paid and that only the allowable amount could be credited.
The annual mass threshold of 50 tonnes excludes many smaller importers of goods, but does not apply to electricity or hydrogen. Initial declarations for goods imported in 2026 are due on 30 September 2027, providing time to reconcile data while leaving limited room for missing factory records.
The Finance Ministry projected potential exposure of EUR 161.4 million in 2029, as free allowances are phased out.
Elevated by CBAM by Clarion Engineer