Serbia’s estimated exposure to the EU’s Carbon Border Adjustment Mechanism (CBAM) was 140.2 million euros in the Ministry of Finance’s 2026 baseline assessment, with iron and steel accounting for the largest portion. Electricity added 21.8 million euros and is subject to different compliance rules, giving Serbia a different exposure mix from the EU-wide import pattern.
Steel and aluminium were the leading commercial categories among 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 CBAM-coded imports of 111.23 billion euros. Together, the metals accounted for 91.29 billion euros, or about 82.1% of the total.
That 82.1% is a market-weighted measure of imports from all non-EU origins, including exempt suppliers; it does not represent the proportion of Serbian exports covered by CBAM. 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 electricity shape Serbia’s exposure
In Serbia’s 2026 baseline, iron and steel made up 89.1 million euros of estimated exposure, compared with 19.5 million euros for aluminium and 21.8 million euros for electricity. Cement and fertilisers accounted for the remainder. Steel producers face the largest estimated cost, while electricity is also an important part of Serbia’s trade with the EU.
Trade composition figures based on 2024 exports provide another measure of the country’s exposure. Steel represented 4.5 percentage points of Serbian exports to the EU, aluminium 2.0 points and electricity 4.7 points, for a CBAM-related share of approximately 11.7%. Metals made up roughly 56% of that covered export share.
The Serbian export shares and the EU’s 2025 import values use different years and denominators, so they are not interchangeable annual rankings. A single approach to CBAM would also miss the difference between a coated-steel coil sold to a processor and a megawatt-hour of Serbian electricity entering Hungary’s power system.
Emissions data and customs codes affect costs
For covered steel products, the CBAM charge is not a simple 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. Importers may use regulatory default values when actual emissions data are unavailable.
Serbia’s Ministry of Finance warned that default factors may exceed actual domestic emissions in some cases, potentially penalising lower-emission plants that cannot substantiate their performance. For aluminium, the initial emissions scope under the current CBAM framework applies in 2026 and focuses on direct emissions.
Aluminium 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 may go beyond the 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 with 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, rather than the EU-wide metals share alone.
Serbia’s immediate policy priorities are to establish a credible plant-level steel emissions baseline, map mill products accurately to EU customs codes and treat electricity trade separately. The different compliance needs of a steel product and a megawatt-hour mean that a common CBAM strategy would not fit both.
Elevated by CBAM.Clarion Engineer
