Serbia’s 2024 export composition shows that electricity accounted for 4.7 percentage points of exports to the EU, while steel represented 4.5 points and aluminium 2.0 points. Together, these categories put the CBAM-related share of exports at approximately 11.7%, with metals making up roughly 56% of that covered share.
Serbia’s Ministry of Finance has separately estimated that more than 12% of the country’s exports to the EU fall within the Carbon Border Adjustment Mechanism (CBAM). That estimate and the export composition figures use different measures and years, as do the Serbian trade data and EU-wide import values, so they should not be treated as interchangeable rankings.
In 2025, EU imports of CBAM-coded goods totalled €111.23 billion. Steel imports were valued at €60.95 billion and aluminium imports at €30.34 billion, or €91.29 billion combined—about 82.1% of the total. This 82.1% reflects imports from all non-EU origins, including exempt suppliers; it is not the share of Serbian exports covered by CBAM.
Serbia’s baseline includes metals and electricity
The Ministry of Finance’s 2026 baseline assessment put Serbia’s estimated CBAM exposure at €140.2 million. Iron and steel accounted for €89.1 million, aluminium for €19.5 million and electricity for €21.8 million, with cement and fertilisers making up the remainder. Steel producers had the largest estimated exposure, while electricity was also an important part of Serbia’s trade with the EU and requires a separate compliance approach.
The products involved differ in practical terms: a coated-steel coil sold to a processor is not the same as a megawatt-hour of Serbian electricity entering Hungary’s power system. A uniform approach would not reflect that distinction.
Plant data and product codes shape compliance
For covered steel products, the CBAM charge is not a simple carbon surcharge calculated on invoice value. It depends on a plant’s direct process emissions, its verified production route, eligible input materials and the EU free-allocation adjustment.
Where actual emissions data are unavailable, importers can use regulatory default values. Serbia’s Ministry of Finance warned that these factors may exceed actual domestic emissions in some cases, potentially penalising lower-emission plants that cannot substantiate their performance.
Under the current CBAM framework, aluminium’s initial emissions scope applies in 2026 and focuses on direct emissions. Producers may still face commercial pressure from customers to disclose the sources of their electricity and indirect footprints for decarbonisation strategies. Buyers’ preferences for low-carbon electricity can extend beyond emissions included in the legal certificate calculation, so the two should not be conflated in pricing.
Serbian producers compete with suppliers from China, Türkiye and India, as well as lower-carbon plants inside the EU. Retaining customers depends on actual emissions, data assurance and product economics for the relevant CN8 customs code, rather than the EU-wide metals share alone. The immediate priorities identified for Serbia are to establish a credible plant-level baseline for steel emissions, map mill products accurately to EU customs codes and handle electricity trade separately.
Elevated by CBAM by Clarion Engineer
