Serbia’s Finance Ministry estimates potential exposure of EUR 140.2 million in 2026 under the European Union’s Carbon Border Adjustment Mechanism (CBAM). The estimate covers iron and steel, aluminium, electricity, fertilisers and cement. EU importers are legally responsible for emissions declarations and surrendering CBAM certificates, but Serbian suppliers could bear part of the cost through contract pricing or lower sale prices.
The ministry’s indicative scenario uses 2025 export volumes, default emissions factors and a carbon reference price of EUR 75.36 per tonne. It allocates 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 said these are indicative scenarios, not fixed liabilities.
Under the EU framework, an importer or eligible indirect customs representative must obtain authorisation, report embedded emissions and surrender the required certificates. Importers may seek emissions data supported by verification to avoid costly default values. They may also pass some or all of the expected charge to suppliers under contract terms or include it in resale prices.
Contract terms determine how costs are shared
When a buyer has strong negotiating power or can switch to alternative European supply, a Serbian producer may have to accept a lower net ex-works price. The supply contract’s pricing formula is a better guide to the economic burden than the party named on the customs declaration. Legal responsibility for the declaration therefore does not determine who ultimately bears the charge.
Charges may move through several stages of a supply chain, be spread across product grades, or be recovered through wholesale trading margins and bilateral supply contracts. A Polish steel service centre, for example, could pass a charge to a metal fabricator supplying a German machine maker. An aluminium distributor could spread it across grades, while a power importer could recover it through a trading margin or bilateral deal.
For large buyers of steel and aluminium, practical concerns include emissions pricing, facility verification, contractual indemnities and financing certificate purchases. Producers with verifiably lower emissions or specialist specifications may be better placed to defend margins, while commodity sellers facing intense competition may be pressed to absorb costs. Consumers could also pay higher prices without having any direct CBAM registration obligation.
Certificate prices, carbon charges and reporting dates
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 prices can vary, a static assumption may not reflect the eventual bill. Multiplying the full carbon price by every tonne of gross emissions is not a substitute for the applicable legal calculation, which also 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. That recognition is an 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.
The annual mass threshold of 50 tonnes excludes many smaller importers of goods, but does not apply to electricity or hydrogen. Initial declarations for goods imported in 2026 are due on 30 September 2027, leaving time to reconcile data but little room for missing factory records. The Finance Ministry projects potential exposure of EUR 161.4 million in 2029 as free allowances are phased out.
Elevated by CBAM by Clarion Engineer
