Serbia’s Finance Ministry estimates potential CBAM exposure of EUR 140.2 million in 2026 for Serbian exports to the European Union. The estimate covers iron and steel, aluminium, electricity, fertilisers and cement. Under the EU framework, EU importers are legally responsible for emissions declarations and for surrendering CBAM certificates, while Serbian suppliers could still face part of the cost through contract pricing or lower sale prices.
The ministry’s indicative scenario is based on 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, EUR 21.8 million to electricity, EUR 7.8 million to fertilisers and EUR 1.9 million to cement. The ministry described the figures as indicative scenarios rather than fixed liabilities.
EU CBAM compliance duties and use of verified emissions data
Under the EU CBAM rules, an importer or an eligible indirect customs representative must obtain authorisation to participate in the scheme. They are required to report embedded emissions and surrender the certificates corresponding to those emissions. Importers may seek emissions data supported by verification to avoid relying on costly default values.
In addition to reporting and certificate surrender, the EU framework allows importers to manage how costs flow through commercial arrangements. The ministry noted that expected charges can be passed to suppliers under contract terms or included in resale prices. The economic impact therefore depends on how contracts allocate responsibility between trading parties.
How contract pricing can shift CBAM-related costs
Contract terms determine how CBAM-related 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 accept a lower net ex-works price. The ministry said the party named on the customs declaration does not automatically determine who ultimately bears the charge.
Charges can also move across multiple stages of a supply chain or be spread across product grades. They may be recovered through wholesale trading margins or bilateral supply contracts, depending on commercial structures. 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 grades, and a power importer recovering charges through trading margins or bilateral deals.
For large buyers of steel and aluminium, practical issues highlighted by the ministry include emissions pricing, facility verification, contractual indemnities and financing certificate purchases. Producers with verifiably lower emissions or specialist specifications may be better positioned to defend margins, while commodity sellers facing intense competition may be pressured to absorb costs. Consumers could also face higher prices even without any direct CBAM registration obligation.
Certificate price movements and Serbia’s carbon tax assumption
The published EU CBAM certificate price was EUR 82.32 per tonne in the third quarter of 2026, compared with EUR 75.36 in the first quarter. Because certificate prices can change over time, using a single static assumption may not match the final bill under CBAM calculations. The ministry also noted that multiplying a carbon price by gross emissions is not a substitute for the legal calculation, which depends on product emissions, EU free-allocation adjustments and eligible carbon prices paid in the producing country.
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, requiring evidence of the qualifying carbon price actually paid and limiting credits to the allowable amount.
Thresholds and reporting deadlines for 2026 imports
The annual mass threshold of 50 tonnes excludes many smaller importers of goods under CBAM reporting obligations. The threshold does not apply to electricity or hydrogen imports. For goods imported in 2026, initial declarations are due on 30 September 2027, allowing time for reconciliation but leaving limited room for missing factory records.
The Finance Ministry projects potential exposure of EUR 161.4 million in 2029 as free allowances are phased out. This projection is linked to changes in free allocation under the EU framework as allowances decline over time.
Elevated by CBAM by Clarion Engineer