Serbia’s Finance Ministry estimated potential exposure of 140.2 million euros in 2026 under the European Union’s Carbon Border Adjustment Mechanism (CBAM), while Serbian suppliers could bear some of the economic cost through contract pricing and lower sale prices. The estimate is an indicative scenario, but it highlights how CBAM costs may affect exporters even though the formal obligations sit with EU-based parties.
EU importers are legally responsible for declaring embedded emissions in covered goods and surrendering the required CBAM certificates. The EU framework assigns authorisation, emissions reporting and certificate surrender to the importer or an eligible indirect customs representative. That allocation of legal duties does not by itself determine who ultimately pays.
The Finance Ministry’s 2026 scenario used 2025 export volumes, default emissions factors and a carbon reference price of 75.36 euros per tonne. It attributed 89.1 million euros to iron and steel, 19.5 million euros to aluminium, 21.8 million euros to electricity, 7.8 million euros to fertilisers and 1.9 million euros to cement. The ministry described the totals as indicative, rather than fixed liabilities, and projected potential exposure of 161.4 million euros in 2029 as EU free allowances phase out.
Contract terms shape who pays
An EU importer may seek verified emissions data to avoid expensive default values, transfer some or all of the expected CBAM cost to a Serbian supplier through contract terms, or include it in resale prices. Where a buyer has strong negotiating power or access to alternative European supply, the Serbian producer may face a lower net ex-works price. The supply contract’s pricing formula can therefore offer a better guide to the economic burden than the party named on the customs declaration.
Costs may also pass beyond the first importer, be spread across product grades or be recovered through wholesale trading margins or bilateral supply contracts. A Polish steel service centre could pass a charge to a metal fabricator that supplies a German machine maker. An aluminium distributor could spread a charge across several product grades, while a power importer could recover it through a wholesale trading margin or bilateral supply contract.
For large steel and aluminium buyers, practical concerns include emissions pricing, facility verification, contractual indemnities and funding certificate purchases. Producers with verifiably lower emissions and specialist specifications may defend their margins, while commodity sellers facing intense competition may be pressured to absorb costs. Consumers could face higher prices without any direct obligation to register under CBAM.
The eventual economic burden depends on contract pricing and bargaining conditions, as well as certificate prices, product-specific emissions calculations, EU free-allocation adjustments and eligible carbon prices already paid in the producing country. The EU’s published CBAM certificate price was 82.32 euros per tonne in the third quarter of 2026, up from 75.36 euros per tonne in the first quarter. Because prices can vary, static assumptions are risky; multiplying the full carbon price by every tonne of gross emissions is not a substitute for the applicable legal calculation.
Domestic carbon pricing and reporting dates
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. That recognition is a modelling assumption, not a legal guarantee; 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. First declarations for goods imported in 2026 are due on 30 September 2027. The deadline leaves time for data reconciliation, but little room for missing factory records.
Elevated by CBAM.Clarion Engineer