Serbia’s Finance Ministry estimated potential exposure of 140.2 million euros in 2026 under the European Union’s Carbon Border Adjustment Mechanism (CBAM), using 2025 export volumes. Although EU importers are legally responsible for emissions declarations and certificates, Serbian suppliers may bear some of the economic cost through contract pricing and lower sale prices.
Under the EU framework, the importer or an eligible indirect customs representative must obtain authorisation, report emissions embedded in covered goods and surrender the required certificates. Importers may seek verified emissions data to avoid expensive default values, transfer some or all of the expected CBAM cost to a supplier through contract terms, or include it in resale prices.
The ministry’s indicative scenario used default emissions factors and a carbon reference price of 75.36 euros per tonne. It attributed 89.1 million euros 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. The ministry described the figures as indicative scenarios, not fixed liabilities.
Contract terms determine cost sharing
A buyer with strong negotiating power or access to alternative European supply may press a Serbian producer to accept a lower net ex-works price. The supply contract’s pricing formula is a better indicator of who ultimately bears CBAM costs than the party named on the customs declaration.
Charges 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 supplying a German machine maker. An aluminium distributor could spread a charge across grades, while a power importer could recover it through a 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 or specialist specifications may defend their margins, while commodity sellers facing intense competition may be pressured to absorb costs. Consumers may also face higher prices without having a direct obligation to register under CBAM.
Prices, domestic carbon tax and deadlines
The EU’s published CBAM certificate price was 82.32 euros per tonne in the third quarter of 2026, compared with 75.36 euros in the first quarter. Because certificate prices can vary, static assumptions are risky. Multiplying the full carbon price by every tonne of gross emissions is not a substitute for the legal calculation, which depends on product-specific emissions, EU free-allocation adjustments and eligible carbon prices already paid in the producing country.
Serbia introduced a greenhouse-gas emissions tax in January 2026 at a stated headline rate of 4 euros per tonne of CO2-equivalent. In a modeled scenario, the ministry put potential 2026 exposure at 127.3 million euros if the EU fully recognises domestic carbon pricing, down from 140.2 million euros. That 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 from CBAM, but does not apply to electricity or hydrogen. The ministry projected potential exposure of 161.4 million euros in 2029 as free allowances phase out.
First declarations for goods imported in 2026 are due on 30 September 2027. The deadline leaves time to reconcile data but little room for missing factory records.
Elevated by CBAM.Clarion Engineer
