For Serbian steel and aluminium producers exporting to the EU, Turkish raw-material suppliers are becoming part of the CBAM evidence chain, not just the procurement chain. The practical issue is not whether Turkey itself is in the EU’s Carbon Border Adjustment Mechanism. The issue is whether a Serbian exporter can prove, product by product and batch by batch, the embedded emissions of Turkish-origin steel or aluminium inputs that are transformed in Serbia and then sold into the EU.
CBAM is now moving from reporting into financial exposure. The definitive regime started on 1 January 2026. EU importers of covered goods must operate through an authorised CBAM declarant, report embedded emissions and surrender CBAM certificates linked to the EU ETS price, while any eligible carbon price paid during production can be deducted. The Commission’s first quarterly CBAM certificate price for Q1 2026 was €75.36/tCO₂e.
This matters directly for Serbia because metals exports to the EU are already material. In 2025, EU imports from Serbia included around €599 million of iron and steel and €863 million of non-ferrous metals, while EU exports to Serbia also included substantial metal flows. That makes Serbia not a marginal CBAM case, but a live industrial supply-chain case where Turkish, Serbian and EU data must connect.
The Serbian producer base is split between very different carbon profiles. HBIS Serbia in Smederevo operates an integrated steel platform with around 2.2 million tonnes/year of capacity and flat-steel products such as hot-rolled coil, cold-rolled coil, pickled coil and tinplate. Metalfer is positioned around scrap-based steelmaking and long products, with its own rebar, coil and wire-rod chain. Impol Seval is Serbia’s major rolled-aluminium platform, producing aluminium rolled materials for international customers and investing in furnace modernisation to reduce gas and energy use.
The Turkish supplier universe should therefore be treated as a screening map, not as a list of confirmed direct contracts unless invoices, customs data or mill certificates prove the link. For Serbian steel producers and processors, relevant Turkish counterparties include flat-steel and coated-steel suppliers such as Erdemir, whose product range includes hot-rolled, cold-rolled, galvanised and tin/chrome-coated flat products, and long-product or semi-finished suppliers such as Kardemir Çelik, which describes a chain covering steelmaking, billets, profiles, rebar and wire rod.
For Serbian aluminium processors and exporters, the Turkish supplier map is broader. Eti Alüminyum is relevant on the primary aluminium side, with capacity across bauxite processing, alumina and cast aluminium products. Assan Alüminyum is relevant for flat-rolled aluminium, coil, sheet, foil and pre-painted products, with declared installed capacity of up to 360,000 tonnes and export activity across more than 70 countries. ASAŞ is relevant for extrusions, flat-rolled products and aluminium systems, while Teknik Alüminyum is relevant for coil, sheet and strip products across common alloy groups.
The CBAM logic is straightforward but commercially disruptive. The EU importer is responsible for the CBAM declaration when Serbian-origin steel or aluminium goods enter the EU. The Serbian exporter, however, must provide the evidence. When Turkish steel or aluminium is used as a precursor or input in Serbia, the Turkish supplier’s plant-level emissions, production route, energy data and product classification become part of the Serbian exporter’s evidence file. A Turkish input does not automatically create a separate CBAM charge unless it is imported into the EU directly, but its embedded emissions can become part of the embedded-emissions calculation of the Serbian product sold into the EU.
The most important dividing line is the CN code. CBAM is not based on broad commercial descriptions such as “steel input” or “aluminium raw material”. It is based on customs classification. The EU guidance requires operators to map imported CBAM goods by CN code and identify the parameters needed from the producing installation. Covered sectors include iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, with some precursors and downstream products included.
For steel, Serbian exporters need to know whether the Turkish input is billet, slab, hot-rolled coil, cold-rolled coil, coated sheet, wire rod, bar, tube, fastener material or another covered product. The CBAM methodology also requires data such as scrap share, alloying content and precursor emissions. Ferrous waste and scrap are treated differently from steel products, so a scrap-based Serbian chain can have a very different CBAM profile from a blast-furnace or high-primary-material chain, but the scrap claim still has to be documented rather than asserted.
For aluminium, the same principle applies. Unwrought aluminium, aluminium powders, bars, rods, profiles, wire, plates, sheets, strip, foil, tubes, pipe fittings and several downstream aluminium goods are within the CBAM perimeter, while aluminium scrap is excluded. The methodology distinguishes between primary and secondary aluminium and requires attention to direct emissions, indirect emissions during the transitional phase, precursor materials and, for some aluminium production, process emissions such as PFCs.
The minimum CBAM procurement file for a Serbian exporter buying from Turkey should therefore contain the Turkish supplier name, plant name, CN code, non-preferential origin, batch or heat number, mill certificate, product weight, production route, direct emissions in tCO₂e/t, precursor emissions, electricity consumption and emission factor, scrap share, alloy composition, any carbon price paid, and confirmation that the data can survive third-party verification. General ESG documents, ISO certificates, I-REC claims or green-power marketing material are useful only as supporting evidence; they do not replace CBAM-format installation and product data.
The commercial risk is that an EU buyer will start pricing Serbian metal exports according to the weakest part of the evidence chain. A Serbian exporter using Turkish inputs with verified low-carbon data can defend price, contract eligibility and buyer confidence. A Serbian exporter using Turkish inputs without plant-level CBAM data may face buyer discounts, warranty demands, delayed customs handling, higher working-capital pressure or contract clauses shifting future CBAM certificate costs back to the supplier.
Turkey is moving in the same direction, which could eventually help Serbian buyers. Türkiye adopted its first Climate Law in July 2025, creating the legal basis for a national emissions trading system, and its ETS pilot phase is expected to start in 2026. That does not automatically remove CBAM exposure, but it means Turkish steel and aluminium suppliers are under growing pressure to produce EU-compatible MRV data and, over time, may be able to support claims for deductible carbon prices if those payments meet EU requirements.
The next pressure point is downstream expansion. The EU has already signalled movement toward extending CBAM to certain downstream goods and strengthening anti-circumvention rules. That matters for Serbian exporters because the risk will not stop at primary steel, aluminium or simple semi-finished products. More processed goods, assemblies and metal-intensive products may become exposed, especially where the EU sees a risk that production is being shifted just outside the bloc to avoid carbon costs.
The strategic playbook for Serbian producers is therefore clear. HBIS Serbia, Metalfer, Impol Seval and downstream exporters using Turkish inputs need to move from normal procurement to CBAM-qualified procurement. Supplier selection should no longer be based only on price, delivery, alloy quality and payment terms. It should include CBAM data readiness, installation-level emissions, verification discipline, precursor traceability and the supplier’s ability to provide repeatable evidence for every shipment.
The Turkish suppliers that win in Serbia will be those that sell not only metal, coil, billet, foil or profile, but also bankable emissions data. The Serbian exporters that protect EU market access will be those that can show a clean chain from Turkish raw material to Serbian processing plant to EU importer declaration, with carbon cost, product origin and embedded-emissions evidence aligned before the shipment reaches the border.
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