Serbia’s estimated exposure to the European Union’s Carbon Border Adjustment Mechanism (CBAM) is 140.2 million euros in the 2026 baseline assessment, with iron and steel accounting for the largest cost. Electricity adds 21.8 million euros and has different compliance rules, giving Serbia a different exposure profile from the EU’s overall CBAM-coded import mix. Serbia’s Ministry of Finance estimated that more than 12% of the country’s exports to the EU fall within the mechanism’s scope.
Steel and aluminium dominated the value of EU imports of CBAM-coded goods in 2025. Steel imports were valued at 60.95 billion euros and aluminium at 30.34 billion euros, out of total imports of 111.23 billion euros. Together, the two metals were worth 91.29 billion euros, or about 82.1% of the total.
That 82.1% is a market-weighted measure covering imports from all non-EU origins, including exempt suppliers; it is not the share of Serbian exports covered by CBAM. The EU-wide import figures refer to 2025, while Serbia’s export-composition figures are based on 2024 trade, so the two measures should not be treated as interchangeable annual rankings.
Steel leads Serbia’s estimated costs
In the Serbian Ministry of Finance’s 2026 baseline, iron and steel account for 89.1 million euros of estimated exposure, followed by electricity at 21.8 million euros and aluminium at 19.5 million euros. Cement and fertilisers make up the remainder. Steel producers therefore carry the largest estimated cost, while electricity is also an important part of Serbia’s trade with the EU.
On the 2024 trade basis, steel represented 4.5 percentage points of Serbian exports to the EU, aluminium 2.0 percentage points and electricity 4.7 percentage points. Together, these categories formed an approximately 11.7% CBAM-related export share. Metals made up roughly 56% of that covered export share.
The categories also differ in what they represent commercially. A coated-steel coil destined for a processor is not equivalent to a megawatt-hour entering Hungary’s power system, and a single CBAM strategy would not account for those differences.
Emissions data and product codes matter
For covered steel items, the CBAM charge is not a simple carbon surcharge on invoice value. It depends on a plant’s direct process emissions, verified production route, eligible input materials and the EU free-allocation adjustment. The applicable requirements therefore depend on the product and its production data.
When actual emissions data are unavailable, importers may use regulatory default values. Serbia’s Ministry of Finance warned that default factors may exceed actual domestic emissions in some cases, potentially disadvantaging lower-emission Serbian installations that cannot substantiate their performance.
The initial emissions scope for covered aluminium products under the current CBAM framework applies in 2026 and focuses on direct emissions. Producers may still face commercial pressure to disclose electricity sources and indirect footprints for customers’ decarbonisation strategies. A buyer’s preference for low-carbon electricity can extend beyond the electricity emissions included in the legal CBAM 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. Their ability to retain customers depends on actual emissions, data assurance and product economics for the relevant CN8 code, not on the EU-wide metals share alone.
The immediate policy priorities identified for Serbia are to establish a credible plant-level steel emissions baseline, map mill products accurately to EU customs codes and treat electricity trade separately.
Elevated by CBAM.Clarion Engineer