Serbia’s Finance Ministry estimates potential exposure of 140.2 million euros in 2026 under the European Union’s Carbon Border Adjustment Mechanism (CBAM), based on 2025 export volumes. EU importers are legally responsible for declaring embedded emissions and surrendering CBAM certificates, but Serbian suppliers may bear part of the economic cost through contract pricing and lower sale prices. The ministry describes its figures as indicative scenarios, rather than fixed liabilities.
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 suppliers through contract terms, or incorporate it into resale prices.
The ministry’s estimate uses default emissions factors and a carbon reference price of 75.36 euros per tonne. It attributes 89.1 million euros of the 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.
Contract terms shape the economic burden
When a buyer has strong negotiating power or access to alternative European supply, a Serbian producer may face a lower net ex-works price. A supply contract’s pricing formula is a better indicator of who ultimately bears CBAM costs than the identity of the party named on the customs declaration.
Costs 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. For example, a Polish steel service centre could pass a charge to a metal fabricator that supplies a German machine maker. An aluminium distributor could spread a charge across several 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 and specialist specifications may defend their margins, while commodity sellers facing intense competition may be pressured to absorb costs. Consumers may also face higher prices despite having no direct obligation to register under CBAM.
Certificate prices and compliance timing
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. Certificate prices can vary, making static price assumptions risky. Multiplying the full carbon price by every tonne of gross emissions is not a valid substitute for the applicable legal calculation.
The eventual burden also depends on contract pricing and bargaining conditions, product-specific emissions calculations, EU free-allocation adjustments and eligible carbon prices already 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, the Finance Ministry calculates that 2026 exposure would fall from 140.2 million euros to 127.3 million euros if the EU fully recognised Serbia’s domestic carbon pricing. That recognition is an assumption in the ministry’s model, not a legal guarantee. An importer would need evidence of the qualifying carbon price actually paid, and only the allowable amount would be credited.
An annual mass threshold of 50 tonnes excludes many smaller importers of goods from CBAM, but does not apply to electricity or hydrogen. First declarations for goods imported in 2026 are due on 30 September 2027. The deadline leaves time for data reconciliation but little room for missing factory records.
The ministry projects potential exposure of 161.4 million euros in 2029 as free allowances phase out.
Elevated by CBAM.Clarion Engineer