Serbian aluminium exporters are facing broader exposure to the European Union’s Carbon Border Adjustment Mechanism (CBAM), with emissions from upstream aluminium inputs becoming an important part of the compliance process.
- CBAM covers a broad range of aluminium products
- Serbian aluminium processing relies on upstream inputs
- Direct aluminium emissions remain within the definitive scope
- Supplier data becomes part of the export process
- Default emissions values affect CBAM calculations
- Scrap and recycled aluminium require separate tracking
- CBAM data connects procurement, production and customs
- Supplier qualification gains a carbon-data component
- EU customers require additional product information
- Carbon prices add another commercial variable
- Financing and investment implications
- 2026 production data forms the basis for later reporting
EU imports of aluminium and aluminium articles from Serbia reached approximately $505.7 million in 2025, equivalent to around €450 million. A first mapping against current CBAM product headings indicates that about nine tenths of Serbia’s broad aluminium exports to the EU could fall within the mechanism. The largest trade flows included approximately $168 million of aluminium plate, sheet and strip, nearly $89 million of casks, drums and boxes, $70 million of other aluminium articles, almost $50 million of structures, and close to $47 million of bars, rods and profiles.
CBAM covers a broad range of aluminium products
The current CBAM Annex includes unwrought aluminium, powders and flakes, bars, rods and profiles, wire, plates, sheets and strip, foil, tubes, pipe fittings, structures, containers, compressed-gas containers, stranded wire and other specified aluminium products. Two major categories are outside the current Annex I list. Aluminium waste and scrap under HS 7602 and household and sanitary articles under HS 7615 are not currently covered.
EU imports of Serbian aluminium scrap amounted to approximately $39.5 million in 2025. Excluding scrap and other clearly non-covered products from the broader Chapter 76 trade total produces an indicative current CBAM exposure of about $465 million, or approximately €410 million based on the 2025 average dollar-euro relationship. That represents around 92% of Serbia’s broad aluminium trade with the EU, although the precise share requires reconciliation at the CN8 level using Eurostat data.
Serbian aluminium processing relies on upstream inputs
Impol Seval, the aluminium rolling producer in Sevojno, manufactures products including prepainted coils and sheets, cold-rolled coils, hot-rolled coils, hot-rolled plates, sheets and billets. Its products serve the automotive, pharmaceutical, food and beverage, transport, electrical and construction industries. The structure of Serbia’s aluminium trade is closely connected with processing and manufacturing, rather than only primary aluminium production. Rolling, coating, shaping and fabrication form an important part of the domestic value chain.
For processors, this means emissions associated with aluminium inputs can form a significant part of the emissions profile of exported products. The EU noted in its 2025 CBAM changes that embedded emissions in certain steel and aluminium products are primarily determined by the emissions of precursor materials, while finishing operations can generate comparatively low emissions.
Direct aluminium emissions remain within the definitive scope
Aluminium is among the world’s most electricity-intensive industrial materials, but the current definitive CBAM mechanism covers direct embedded emissions for aluminium. Indirect emissions from electricity are outside the definitive aluminium scope. This differs from cement and fertilisers, for which both direct and indirect emissions are included.
As a result, a Serbian aluminium processor does not automatically apply Serbia’s average electricity carbon intensity as a CBAM charge to every exported tonne. Renewable electricity and solar generation can reduce electricity costs and corporate Scope 2 emissions, while supporting sustainability targets and future carbon-related requirements, but they do not by themselves remove the current upstream aluminium emissions exposure. For many Serbian processors, the immediate CBAM issue is therefore the direct emissions embedded in the aluminium precursor.
Supplier data becomes part of the export process
A Serbian processor purchasing aluminium slab, billet or another relevant precursor needs information on the material’s producer, production installation and production route, as well as its embedded direct emissions. Relevant records can include whether the material was produced as primary or secondary aluminium, whether emissions are based on actual or default values, whether actual emissions have been verified, how much precursor entered production, how much was converted into finished products, the volume of process scrap and how emissions are allocated to exported goods.
This creates a direct connection between procurement and EU market requirements. The difference between primary and secondary aluminium is particularly relevant. CBAM’s definitive default-value system distinguishes between primary aluminium and secondary aluminium production routes, while actual emissions can depend on production technology, fuels and material flows.
Default emissions values affect CBAM calculations
EU importers can use Commission default values instead of actual installation data. Under the current framework, applicable default values for aluminium and steel receive a 10% mark-up in 2026, rising to 20% in 2027 and 30% from 2028. For Serbian processors whose supply chains have lower actual emissions, the ability to obtain and document actual supplier data therefore becomes relevant to the calculation. Companies need information on supplier production routes, emissions, precursor quantities and verification status to support the use of actual values.
Scrap and recycled aluminium require separate tracking
The treatment of aluminium scrap under CBAM also depends on how the material enters the production chain. Scrap exported directly under HS 7602 is outside the current Annex I list. When recycled material is processed into a CBAM-covered aluminium product, the production route and emissions associated with the resulting product become relevant.
Processors therefore need records distinguishing purchased scrap, internal process scrap, primary metal and secondary metal, together with supplier declarations, mass-balance information and material genealogy. The calculation methodology also needs to provide an evidence trail that can be followed during independent verification.
CBAM data connects procurement, production and customs
For aluminium processors, emissions reporting can involve the same operational data used by procurement, production, quality, finance, sales, logistics and customs. A typical chain can connect the supplier, purchase order, incoming metal, batch or lot, warehouse, production order, processing route, yield, process scrap, finished product, CN code, sales order, EU customer, customs declaration and authorised CBAM declarant.
The required information may therefore be distributed across multiple company systems. Procurement records the supplier, production tracks batches, quality records alloy information, environmental teams manage emissions data, finance manages inventory, sales manages customers, logistics records shipments and customs identifies CN codes. CBAM requires those records to be reconciled into a single emissions calculation.
Supplier qualification gains a carbon-data component
Verification can assess evidence but cannot create upstream information that a supplier has not provided. For Serbian processors, supplier qualification can therefore include questions about installation-level embedded-emissions data, actual measurements, production routes, independent verification and the ability to provide information within CBAM reporting schedules.
Companies may also need to establish whether suppliers can transfer relevant information to the EU authorised declarant and verifier and maintain the same methodology throughout the contractual period. The requirements can affect supply relationships beyond Serbia. A Serbian processor importing aluminium from another non-EU country and subsequently exporting a CBAM-covered product to the EU can depend on the upstream producer’s emissions data for the competitiveness and compliance position of the final export.
EU customers require additional product information
Traditional aluminium sales can cover alloy, temper, dimensions, tolerances, surface quality, coating, volume, delivery schedules and price. CBAM adds information concerning the production installation, precursor type, primary or secondary aluminium route, embedded emissions, direct emissions from Serbian processing, emissions allocation, use of default values and verification. For EU importers, complete supplier information can support the work of the authorised CBAM declarant and reduce uncertainty over the emissions calculation.
Carbon prices add another commercial variable
The EU published CBAM certificate prices of €75.36 per tonne of CO₂ for the first quarter of 2026 and €75.28 per tonne of CO₂ for the second quarter. The CBAM cost of Serbian aluminium cannot be calculated by applying those prices directly to a headline emissions figure. The mechanism also involves benchmarks, free-allocation adjustments, actual or default emissions and possible deductions for recognised carbon prices paid in the country of origin. Nevertheless, differences between aluminium production routes and their embedded emissions can affect the carbon-cost calculation associated with EU imports.
Financing and investment implications
CBAM exposure can also become relevant to financing for Serbian aluminium processors with substantial EU export revenues. Factors relevant to corporate financing can include the share of revenue generated from EU exports, the proportion of products covered by CBAM, the use of actual or default emissions, the quality of precursor data, supplier concentration, potential carbon-cost pass-through, contractual arrangements with EU customers and investment required to improve emissions performance or measurement, reporting and verification systems. The same information can be relevant to commercial due diligence for investors and potential M&A transactions.
2026 production data forms the basis for later reporting
The European Commission published its definitive-period aluminium guide, Guidance 5e, followed by verification guidance. The first CBAM declaration covering definitive-period 2026 imports is due on September 30, 2027.
Data generated during 2026 production and procurement therefore needs to be preserved for subsequent reporting. Supplier information, precursor flows, production records, inventory, scrap and finished-product data all form part of the evidence required to support emissions calculations. For Serbian aluminium processors, the CBAM process therefore extends from upstream supplier data through production and internal reporting to EU customs and customer requirements.
