Serbia’s steel exports to the European Union are facing simultaneous changes in carbon regulation and market-access rules, affecting a trade flow worth about €1 billion annually. EU imports from Serbia in 2025 included $640.7 million of iron and steel under HS Chapter 72 and $573.5 million of iron and steel articles under Chapter 73, producing a combined trade value of about $1.21 billion. While CBAM does not cover every product in those categories, many of Serbia’s major steel exports are included, including hot-rolled, cold-rolled and coated flat products, structures, tubes and fasteners. EU data supporting the new steel safeguard framework also show imports of the products concerned from Serbia increasing from 657,318 tonnes in 2024 to 760,234 tonnes in 2025, a rise of almost 16%.
- Steel trade extends across Serbia’s industrial supply chain
- Most major steel flows fall within the CBAM framework
- EU steel safeguards add a separate market-access requirement
- Basic-metal production weakens while downstream exports grow
- CBAM requires installation-level emissions data
- Supplier data is becoming part of procurement
- Renewable power does not remove direct steel emissions
- CBAM certificate prices add a direct financial dimension
- Export contracts increasingly need carbon provisions
- Verification requirements bring 2026 production into focus
Steel trade extends across Serbia’s industrial supply chain
The HBIS Group Serbia steelworks in Smederevo is the country’s main primary steel producer, but Serbia’s exposure to CBAM extends across processors, fabricators, construction-product manufacturers and exporters. Chapter 73 imports alone exceeded $570 million in 2025. Major categories included about $209 million of steel structures and structural parts, nearly $147 million of other iron and steel articles, approximately $40 million of tubes and hollow profiles, and more than $26 million of screws, bolts and related fasteners.
Many downstream exporters do not produce crude steel themselves. Their CBAM exposure can nevertheless originate with the steel precursors purchased from upstream suppliers. For manufacturers exporting qualifying products, the embedded emissions of steel entering their facilities can become an important component of the emissions attributed to the finished goods.
Most major steel flows fall within the CBAM framework
The headline value of Serbia’s steel trade should not be treated as an exact measure of CBAM exposure because the mechanism applies according to specific CN codes. Most Chapter 72 products are covered, although exclusions include HS 7204 ferrous waste and scrap and specified ferro-alloys. Chapter 73 contains both covered and excluded product groups. An initial mapping of Serbia’s 2025 trade indicates that about €960 million of the roughly €1.07 billion combined HS72 and HS73 trade envelope falls clearly within current CBAM headings, implying indicative coverage of close to 90%.
The final figure requires reconciliation at CN8 level. The largest Chapter 72 flows included approximately $384 million of hot-rolled flat iron and non-alloy steel, $124 million of coated or plated flat products and $63 million of cold-rolled flat products. Together, those categories represented almost $570 million. By comparison, ferrous scrap, which is outside the current CBAM list, accounted for about $25 million.
EU steel safeguards add a separate market-access requirement
The carbon-border changes coincide with tighter EU trade protection measures for steel. The European Commission adopted rules implementing bilateral safeguard measures for steel products originating in countries with which the EU has free-trade agreements, including Serbia.
Imports of the products covered by the safeguard framework from Serbia amounted to 664,743 tonnes in 2023, 657,318 tonnes in 2024 and 760,234 tonnes in 2025. The increase between 2024 and 2025 was about 15.7%, while the rise over 2023-2025 was reported at 14%. The safeguard product range is not identical to the CBAM scope. For Serbian exporters, however, the two regulatory systems affect the same commercial flows, alongside requirements covering origin, customs treatment, carbon data and CBAM certificate costs.
Basic-metal production weakens while downstream exports grow
Serbia’s domestic industrial data show a decline in primary metals activity during 2026. Output in basic metals fell 12.5% year on year in January-July 2026. At the same time, the National Bank of Serbia reported that exports of fabricated metal products, excluding machinery and equipment, increased 20.8% during the first seven months of the year and provided one of the largest positive contributions to overall export growth. The figures illustrate different developments across Serbia’s metals supply chain, with primary production weakening while downstream exporters continue to record stronger external sales. CBAM links those segments through the emissions information associated with steel precursors.
CBAM requires installation-level emissions data
Steel producers supplying actual emissions data to EU customers must connect the calculations to a defined installation, production process and reporting period. The required evidence includes installation boundaries, production routes, fuel consumption, process emissions, material and energy balances, production volumes, precursor quantities and embedded precursor emissions. Companies also need allocation methodologies, metering and laboratory records, monitoring plans, calculation files, product quantities, CN classifications and links between EU customers and authorised declarants.
Actual emissions values also require independent verification. For downstream manufacturers, obtaining precursor information can be particularly important because accurate calculations depend on the emissions associated with the steel entering the production process.
Supplier data is becoming part of procurement
Steel buyers have traditionally focused procurement on grades, dimensions, chemical specifications, certification, price and delivery. CBAM adds requirements for identifying the producing installation, production route and embedded emissions of purchased material. Companies also need to determine whether emissions data are based on actual verified values or defaults, the quantity purchased and the amount allocated to exported products.
Reconciliation with inventories, scrap, yields and production records is also becoming relevant. Where suppliers cannot provide usable emissions information, EU importers may have to use default values. For iron and steel and aluminium, the applicable default values carry a 10% mark-up in 2026, increasing to 20% in 2027 and 30% from 2028 under the current rules.
Renewable power does not remove direct steel emissions
Renewable electricity investments can reduce energy costs and support broader emissions-reduction efforts, but they do not eliminate current direct CBAM exposure for iron and steel. Under the definitive CBAM framework, iron and steel are subject to direct embedded emissions rather than indirect electricity emissions. For production based on blast-furnace/basic-oxygen-furnace technology, direct emissions from the steelmaking route therefore remain central to the calculation. HBIS Group Serbia has pursued renewable-energy initiatives at its Smederevo site, including plans for solar generation. Those investments are relevant to broader decarbonisation efforts but do not directly offset the current calculation of direct steelmaking emissions.
CBAM certificate prices add a direct financial dimension
The European Commission published a Q1 2026 CBAM certificate price of €75.36 per tonne of CO₂ and €75.28 per tonne for Q2. The CBAM cost for Serbian steel cannot be calculated simply by multiplying total plant emissions by the certificate price. The calculation depends on relevant embedded emissions, the CBAM benchmark and free-allocation adjustment, recognised carbon prices and other regulatory parameters. At around €75 per tonne of CO₂, however, differences in verified emissions can translate into material differences in import economics when applied across large steel volumes.
Export contracts increasingly need carbon provisions
EU steel buyers can require more detailed CBAM provisions from suppliers outside the bloc. Such provisions may address data-delivery deadlines, verification rights, installation information, accuracy warranties, default values, precursor data, allocation methods and liability for incorrect information.
They can also establish cooperation requirements with accredited verifiers. For Serbian exporters, these provisions determine how financial risk is allocated if emissions evidence is incomplete or cannot support the values submitted to the EU importer.
Verification requirements bring 2026 production into focus
The European Commission published definitive-period steel guidance, Guidance 5d, on Aug. 14, followed later in August by guidance on verification and accreditation. Where actual emissions are reported, they must be verified. This makes production records from 2026 relevant to future compliance, including precursor documentation, production boundaries, metering, ERP records, batch allocation and shipment data. For downstream manufacturers, maintaining an auditable connection between purchased steel, production batches, finished products and EU exports is therefore becoming part of the CBAM process.
