Serbia’s Finance Ministry estimates potential exposure of 140.2 million euros in 2026 under the European Union’s Carbon Border Adjustment Mechanism (CBAM). Although EU importers are legally responsible for emissions declarations and surrendering certificates, Serbian suppliers could bear part of the cost through contract pricing or lower sale prices. The legal obligation does not determine who ultimately pays.
The ministry’s indicative scenario uses 2025 export volumes, default emissions factors and a carbon reference price of 75.36 euros per tonne. It estimates exposure of 89.1 million euros for iron and steel, 19.5 million euros for aluminium, 21.8 million euros for electricity, 7.8 million euros for fertilisers and 1.9 million euros for 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 independently verified emissions data to avoid costly default values, 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 passed on
When a buyer has strong negotiating power or can switch to alternative European supply, a Serbian producer may receive a lower net ex-works price. The pricing formula in the supply contract is a better guide to the economic burden than the party named on the customs declaration.
Charges can move through several stages of a supply chain, be distributed 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 steel and aluminium purchasers, practical considerations include emissions pricing, facility verification, contractual indemnities and financing certificate purchases. Producers with verifiably lower emissions or specialist specifications may be better positioned to defend margins, while commodity sellers facing intense competition may be pressed to absorb costs. Consumers could also pay higher prices despite having no direct CBAM registration obligation.
Certificate prices, carbon payments and deadlines
The EU’s published CBAM certificate price reached 82.32 euros per tonne in the third quarter of 2026, compared with 75.36 euros in the first quarter. As prices can vary, a static assumption may not reflect the final 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, with a stated headline rate of 4 euros per tonne of CO2-equivalent. In a modeled scenario, potential 2026 exposure declines from 140.2 million euros to 127.3 million euros if the EU fully recognises domestic carbon pricing. This 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 would be credited.
The annual mass threshold of 50 tonnes excludes many smaller goods importers, but does not apply to electricity or hydrogen. First declarations for goods imported in 2026 are due by 30 September 2027, allowing time to reconcile data but leaving little room for missing factory records. The Finance Ministry projects potential exposure of 161.4 million euros in 2029 as free allowances are phased out.
Elevated by CBAM by Clarion Engineer