Serbia faces more than 140 million euros in potential exposure under the EU’s Carbon Border Adjustment Mechanism for 2026. Serbia’s Finance Ministry estimated potential 2026 CBAM exposure at 140.2 million euros. The ministry said Serbian suppliers could bear part of the economic cost through contract pricing and lower sale prices, even though the EU framework places compliance steps on EU importers.
Under CBAM, EU importers are legally responsible for declaring embedded emissions and surrendering certificates, but that responsibility does not determine who ultimately pays. The EU framework assigns authorisation, emissions reporting and certificate surrender to the importer or an eligible indirect customs representative. Importers may seek verified emissions data to avoid expensive default values, transfer expected costs to Serbian suppliers through contract terms, or include them in resale prices.
Finance Ministry assumptions for 2026 CBAM exposure
The Finance Ministry’s indicative scenario used 2025 export volumes, default emissions factors and a carbon reference price of 75.36 euros per tonne. It allocated 89.1 million euros of estimated 2026 exposure to iron and steel. Other allocations were 19.5 million euros for aluminium, 21.8 million euros for electricity, 7.8 million euros for fertilisers and 1.9 million euros for cement.
The ministry described the figures as indicative scenarios rather than fixed liabilities. It projected potential exposure of 161.4 million euros in 2029 as EU free allowances phase out. The eventual burden depends on product-specific emissions calculations, certificate prices, free-allocation adjustments and eligible carbon prices already paid in the producing country.
Contract terms and supply-chain cost allocation
The ministry said contract terms can determine how costs are shared between buyers and Serbian producers. Where a buyer has strong negotiating power or access to alternative European supply, a Serbian producer may face a lower net ex-works price. In that case, the contract’s pricing formula is presented as a better indicator of cost allocation than the party named on the customs declaration.
CBAM-related costs can move across multiple stages of a supply chain and across product grades. They may also be recovered through wholesale trading margins or bilateral supply contracts. The ministry cited examples including a Polish steel service centre passing a charge to a metal fabricator supplying a German machine maker, an aluminium distributor spreading charges across product grades, and a power importer recovering costs through wholesale trading margins or bilateral contracts.
Compliance considerations for buyers and reporting obligations
The ministry highlighted practical concerns for large steel and aluminium buyers, including emissions pricing, facility verification, contractual indemnities and funding certificate purchases. It said producers with verifiably lower emissions or specialist specifications may defend their margins. Commodity sellers facing intense competition may be pressured to absorb costs.
The ministry also noted that consumers may face higher prices even without any direct obligation to register under CBAM. Separately, it said Serbia introduced a national greenhouse-gas emissions tax in January 2026 with a stated headline rate of 4 euros per tonne of CO2-equivalent. In a Finance Ministry model, potential 2026 exposure falls from 140.2 million euros to 127.3 million euros if the EU fully recognises domestic carbon pricing.
The ministry described full recognition as a model assumption rather than a legal guarantee. It said an importer would need evidence of the qualifying carbon price actually paid, and only the allowable amount could be credited. An annual mass threshold of 50 tonnes excludes many smaller goods importers from CBAM but does not apply to electricity or hydrogen.
Cerificate prices and CBAM declaration timing in 2026 imports
The EU’s published CBAM certificate price was 82.32 euros per tonne in the third quarter of 2026, compared with 75.36 euros per tonne in the first quarter. The ministry said that because certificate prices can vary, static assumptions may not reflect eventual cost outcomes. It also stated that multiplying the full carbon price by every tonne of gross emissions is not a substitute for the applicable legal calculation.
The ministry set out that first declarations for goods imported in 2026 are due on 30 September 2027. It said this timetable leaves time for data reconciliation but provides limited room for missing factory records.
Elevated by CBAM.Clarion Engineer