Serbia’s Ministry of Finance estimated the country’s 2026 Carbon Border Adjustment Mechanism (CBAM) exposure to the European Union at €140.2 million. The estimate identifies iron and steel as the largest component, while electricity adds €21.8 million. Electricity is treated under different compliance rules, resulting in an exposure mix that differs from the EU-wide pattern of CBAM-coded imports.
EU import data for 2025 show that steel and aluminium together accounted for about 82.1% of the value of CBAM-coded goods imported from non-EU origins. Steel imports were valued at €60.95 billion and aluminium at €30.34 billion, compared with a total of €111.23 billion for all CBAM-coded goods. Combined, the two metals were worth €91.29 billion.
The 82.1% share refers to imports from all non-EU origins, including exempt suppliers, and is not the proportion of Serbian exports covered by CBAM. Serbia’s Ministry of Finance estimates that more than 12% of the country’s exports to the EU fall within the mechanism’s scope. The figures also reflect that covered trade can be measured differently depending on whether import values or export shares are used.
CBAM-covered trade mix: baseline exposure and export composition
In a 2026 baseline assessment, iron and steel account for €89.1 million of Serbia’s estimated CBAM exposure. Electricity follows at €21.8 million, and aluminium is estimated at €19.5 million. Cement and fertilisers make up the remainder of the estimate.
The Ministry of Finance data indicate that steel producers carry Serbia’s largest estimated cost within the covered categories. Electricity is also described as an important part of Serbia’s trade with the EU under CBAM-related coverage. The assessment distinguishes between product categories rather than treating exposure as a single uniform stream.
A separate measure based on 2024 exports provides a different view of covered trade composition. Steel represents 4.5 percentage points of Serbian exports to the EU, aluminium accounts for 2.0 points, and electricity contributes 4.7 points. Together, these categories make up approximately 11.7%, with metals representing roughly 56% of that share.
The export-based figures and EU import values use different years and denominators, so they are not interchangeable annual rankings. Product coverage also varies by compliance requirements and commercial arrangements, including differences between a coated-steel coil sold to a processor and a megawatt-hour of electricity entering Hungary’s power system.
How CBAM charges are determined for steel and aluminium
For covered steel items, the CBAM charge is not described as a simple surcharge on invoice value. It depends on plant-level direct process emissions, a verified production route, eligible input materials, and an EU free-allocation adjustment. Importers may use regulatory default values when actual emissions data are unavailable.
The Ministry of Finance has warned that default factors may exceed actual domestic emissions in some cases. This could affect lower-emission Serbian installations if they cannot substantiate performance with actual data. As a result, the cost for each covered product depends on plant-level emissions and relevant product information.
For covered aluminium products under the current CBAM framework, the initial emissions scope applies in 2026 and focuses on direct emissions. Producers may still face commercial pressure to disclose electricity sources and indirect footprints to support customers’ decarbonisation strategies. A buyer’s preference for low-carbon electricity can extend beyond emissions included in the legal CBAM certificate calculation.
Policy priorities for mapping products and separating electricity trade
Serbian producers compete with suppliers from China, Türkiye and India, as well as lower-carbon plants inside the EU. Customer retention is described as depending on actual emissions, data assurance, and product economics for the relevant CN8 code rather than on an EU-wide metals share alone.
The immediate policy priorities identified for Serbia include establishing a credible plant-level steel emissions baseline. They also include mapping mill products accurately to EU customs codes and treating electricity trade separately from industrial products. These priorities reflect distinct requirements for industrial goods versus power exports rather than a single approach to Serbia’s overall CBAM exposure.
Elevated by CBAM.Clarion Engineer