Serbia’s estimated exposure to the EU Carbon Border Adjustment Mechanism (CBAM) stood at €140.2 million in the Ministry of Finance’s 2026 baseline assessment, with iron and steel accounting for the largest share. Electricity added €21.8 million, giving Serbia a different exposure profile from the EU-wide import mix and requiring a separate compliance approach. The ministry estimated that more than 12% of Serbia’s exports to the EU fall within CBAM scope.
Across all non-EU origins, imports of CBAM-coded goods into the EU in 2025 totalled €111.23 billion. Steel accounted for €60.95 billion and aluminium for €30.34 billion; together, the metals represented €91.29 billion, or about 82.1% of the total. That 82.1% is a market-weighted share that includes imports from exempt suppliers, not the proportion of Serbian exports covered by CBAM.
Serbia’s exposure includes metals and power
In the 2026 Serbian baseline, iron and steel made up €89.1 million of estimated exposure, compared with €19.5 million for aluminium and €21.8 million for electricity. Cement and fertilisers accounted for the remainder. Steel producers face the largest estimated cost, while electricity also forms an important part of Serbia’s trade with the EU.
Serbia’s export composition offers another measure of exposure, using 2024 trade data. Steel represented 4.5 percentage points of exports to the EU, aluminium 2.0 points and electricity 4.7 points, producing an estimated CBAM-related share of approximately 11.7%. Metals accounted for roughly 56% of that covered export share.
The Serbian export shares and EU import values relate to different years and use different denominators, so they are not directly comparable rankings. A uniform approach would also overlook the difference between a coated-steel coil sold to a processor and a megawatt-hour of Serbian electricity entering Hungary’s power system.
Compliance depends on plant data and product codes
For covered steel products, the charge is not a straightforward 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 these values may exceed actual domestic emissions in some cases, potentially penalising lower-emission plants that cannot substantiate their performance.
Under the current CBAM framework, aluminium’s initial emissions scope applies in 2026 and covers direct emissions. Producers may still face commercial pressure from customers to disclose the sources of their electricity and indirect footprints for decarbonisation strategies. A buyer’s preference for low-carbon electricity may extend beyond emissions included in the legal 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 within the EU. Their ability to retain customers depends on actual emissions, data assurance and product economics for the relevant CN8 customs code, rather than the EU-wide metals share alone. Serbia’s immediate priorities are to establish a credible plant-level baseline for steel emissions, map mill products accurately to EU customs codes and handle electricity trade separately.
Elevated by CBAM by Clarion Engineer