Serbia’s Ministry of Finance estimates the country’s exposure to the European Union’s Carbon Border Adjustment Mechanism (CBAM) at 140.2 million euros in its 2026 baseline assessment, with iron and steel the largest component. Electricity adds 21.8 million euros and requires a separate compliance approach from metals, giving Serbia a different exposure mix from the EU’s overall CBAM-coded imports.
Steel and aluminium were the leading commercial categories in the EU’s 2025 CBAM-coded imports. Steel imports were valued at 60.95 billion euros and aluminium at 30.34 billion euros, against 111.23 billion euros for all CBAM-coded goods. Combined, the metals accounted for 91.29 billion euros, or about 82.1% of the total.
That 82.1% is a market-weighted share of imports from all non-EU origins, including exempt suppliers, and does not represent 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 are within scope.
Serbia’s exposure includes significant electricity trade
In the 2026 baseline, the Ministry estimates exposure from iron and steel at 89.1 million euros, aluminium at 19.5 million euros and electricity at 21.8 million euros. Cement and fertilisers account for the remainder. Steel producers face the largest estimated cost, while electricity is also an important part of Serbia’s trade with the EU and is subject to different compliance rules.
Trade data for 2024 show steel made up 4.5 percentage points of Serbian exports to the EU, aluminium 2.0 points and electricity 4.7 points. Together, these categories represented approximately 11.7% of exports on that CBAM-related basis, with metals accounting for roughly 56% of the covered export share. The Serbian figures use a different year and denominator from the EU-wide 2025 import values, so the shares are not interchangeable annual rankings.
A uniform approach would also miss the distinction between a coated-steel coil sold to a processor and a megawatt-hour of Serbian electricity entering Hungary’s power system. The immediate priorities identified for Serbia are a credible plant-level steel emissions baseline, accurate mapping of mill products to EU customs codes and separate treatment of electricity trade.
Emissions data and customs codes affect costs
For covered steel products, the CBAM charge is not a simple carbon surcharge 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. Importers may use regulatory default values when actual emissions data are unavailable.
Serbia’s Ministry of Finance warned that default factors may exceed actual domestic emissions in some cases. That could disadvantage lower-emission Serbian installations unable to substantiate their performance with emissions data. Producers compete with suppliers from China, Türkiye and India, as well as lower-carbon plants inside the EU.
The initial 2026 CBAM emissions scope for covered aluminium products focuses on direct emissions. Producers may still face commercial pressure from customers to disclose electricity sources and indirect footprints for decarbonisation strategies. A buyer’s preference for low-carbon electricity can go beyond emissions included in the legal CBAM certificate calculation, and the two should not be conflated in pricing.
For Serbian producers, retaining customers depends on actual emissions, data assurance and product economics for the relevant CN8 code, rather than the EU-wide metals share alone.
Elevated by CBAM.Clarion Engineer