Serbia’s Finance Ministry estimated potential exposure of 140.2 million euros in 2026 under the European Union’s Carbon Border Adjustment Mechanism (CBAM), while Serbian suppliers may bear part of the economic cost through contract pricing and lower sale prices. EU importers are legally responsible for declaring embedded emissions and surrendering certificates, but that formal obligation does not determine who ultimately pays.
Under the EU framework, the importer or an eligible indirect customs representative is responsible for authorisation, emissions reporting and certificate surrender. Importers may use contract terms to transfer some or all of the expected cost to a Serbian supplier, request verified emissions data to avoid expensive default values, or include charges 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 attributed 89.1 million euros 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.
Contract terms shape the burden
A Serbian producer may receive a lower net ex-works price if a buyer has strong negotiating power or access to alternative European supply. The pricing formula in the supply contract is a better guide to who bears the cost than the name on the customs declaration.
CBAM charges can pass 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 could pass a charge to a metal fabricator supplying a German machine maker. An aluminium distributor could spread a charge across 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 deadlines
The EU’s published CBAM certificate price was 82.32 euros per tonne in the third quarter of 2026, compared with 75.36 euros in the first quarter. Because certificate prices vary, static price 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, which depends on product-specific emissions, EU free-allocation adjustments and eligible carbon prices paid in the producing country.
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 modeled scenario, potential 2026 exposure falls to 127.3 million euros 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.
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 September 30, 2027, allowing time for data reconciliation but leaving little room for missing factory records.
As free allowances phase out, the Finance Ministry projects potential exposure of 161.4 million euros in 2029.
Elevated by CBAM.Clarion Engineer