Serbia’s Finance Ministry estimated potential 2026 CBAM exposure of 140.2 million euros, while Serbian suppliers could bear some of the economic cost through contract pricing and lower sale prices. Under the European Union’s Carbon Border Adjustment Mechanism (CBAM), EU importers are legally responsible for declaring embedded emissions and surrendering certificates, but that legal obligation does not determine who ultimately pays.
The EU framework assigns authorisation, emissions reporting and certificate surrender to the importer or an eligible indirect customs representative. Importers may seek verified emissions data to avoid expensive default values, transfer some or all of the expected cost to a Serbian supplier through contract terms, or include it in resale prices.
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, 19.5 million euros to aluminium, 21.8 million euros to electricity, 7.8 million euros to fertilisers and 1.9 million euros to cement. The ministry described the figures as indicative scenarios, not fixed liabilities.
It projected potential exposure of 161.4 million euros in 2029 as EU free allowances phase out. The eventual burden also depends on product-specific emissions calculations, certificate prices, free-allocation adjustments and eligible carbon prices already paid in the producing country.
Contract terms determine cost allocation
Where a buyer has strong negotiating power or access to alternative European supply, a Serbian producer may face a lower net ex-works price. The contract’s pricing formula is therefore a better indicator of who bears the cost than the party named on the customs declaration.
CBAM costs may move through several stages of a supply chain, be spread across product grades, or be recovered through wholesale trading margins or bilateral supply contracts. For example, a Polish steel service centre could pass a charge to a metal fabricator supplying a German machine maker. An aluminium distributor could spread a charge across product grades, while a power importer could recover it through a wholesale trading margin or bilateral supply contract.
For large steel and aluminium buyers, practical concerns include emissions pricing, facility verification, contractual indemnities and funding certificate purchases. Producers with verifiably lower emissions or specialist specifications may defend their margins, while commodity sellers facing intense competition may be pressured to absorb costs. Consumers may also face higher prices without any direct obligation to register under CBAM.
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 prices can vary, static assumptions may not reflect the eventual cost. Multiplying the full carbon price by every tonne of gross emissions is not a substitute for the applicable legal calculation.
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 exposure falls from 140.2 million euros to 127.3 million euros if the EU fully recognises domestic carbon pricing. That recognition is a model 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.
An annual mass threshold of 50 tonnes excludes many smaller goods importers from CBAM, but does not apply to electricity or hydrogen. First declarations for goods imported in 2026 are due on 30 September 2027, leaving time for data reconciliation but little room for missing factory records.
Elevated by CBAM.Clarion Engineer
