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’s estimate also indicates that Serbian suppliers could absorb part of the economic cost through contract pricing and lower sale prices.
Under CBAM, EU importers are legally responsible for declaring embedded emissions and surrendering certificates. That legal responsibility does not, by itself, determine who ultimately pays within commercial contracts. The EU framework assigns authorisation, emissions reporting and certificate surrender to the importer or an eligible indirect customs representative.
Finance Ministry scenario for 2026 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.
How contract terms can shift CBAM costs
The EU importer’s compliance role can differ from how costs are allocated commercially. Importers may seek verified emissions data to avoid expensive default values, transfer some or all of expected costs to a Serbian supplier through contract terms, or include costs in resale prices.
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 context, the contract’s pricing formula can be a better indicator of cost allocation than the party named on the customs declaration.
CBAM-related charges can move through multiple stages of a supply chain and be spread across product grades. They may also be recovered through wholesale trading margins or bilateral supply contracts, depending on commercial arrangements between parties.
An example cited in the ministry material describes a Polish steel service centre passing a charge to a metal fabricator supplying a German machine maker. It also notes that an aluminium distributor could spread charges across product grades, while a power importer could recover costs through wholesale trading margins or bilateral supply contracts.
Certificate prices and reporting timetable
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. Because certificate prices can change over time, static assumptions may not reflect eventual costs.
The material also states that multiplying the full carbon price by every tonne of gross emissions is not a substitute for the applicable legal calculation. It highlights that CBAM calculations rely on specific legal requirements rather than simplified carbon-price multiplication.
An annual mass threshold of 50 tonnes excludes many smaller goods importers from CBAM, but it does not apply to electricity or hydrogen. First declarations for goods imported in 2026 are due on 30 September 2027, with time for data reconciliation but limited room for missing factory records.
Serbia’s carbon tax and potential CBAM crediting
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 CBAM exposure falls from 140.2 million euros to 127.3 million euros if the EU fully recognises domestic carbon pricing.
The ministry material specifies that such recognition is a model assumption rather than a legal guarantee. Importers would need evidence of the qualifying carbon price actually paid, and only the allowable amount could be credited under CBAM rules.
Operational considerations for buyers and producers
The ministry material lists practical considerations for large steel and aluminium buyers including emissions pricing, facility verification, contractual indemnities and funding certificate purchases. It also notes that producers with verifiably lower emissions or specialist specifications may defend their margins.
For commodity sellers facing intense competition, the material says they may be pressured to absorb costs. It also states that consumers may face higher prices even without any direct obligation to register under CBAM.
Elevated by CBAM.Clarion Engineer