Serbia’s Finance Ministry estimates potential exposure of 140.2 million euros in 2026 under the European Union’s Carbon Border Adjustment Mechanism (CBAM). EU importers are legally responsible for emissions declarations and surrendering CBAM certificates, but Serbian suppliers could bear part of the cost through contract pricing or lower sale prices. The party named on the customs declaration is therefore not necessarily the party that ultimately pays.
Under the EU framework, an importer or an eligible indirect customs representative must obtain authorisation, report embedded emissions and surrender the required certificates. An importer can seek emissions data verified for CBAM reporting to avoid costly default values, pass some or all of the expected charge to a supplier under contract terms, or include it in resale prices.
The Finance Ministry’s indicative 2026 scenario applies 2025 export volumes, default emissions factors and a carbon reference price of 75.36 euros per tonne. It allocates 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 said these are indicative scenarios, not fixed liabilities.
Contract terms determine how costs are passed on
A Serbian producer may receive a lower net ex-works price if a buyer has strong negotiating power or can switch to alternative European supply. The pricing formula in the supply contract is a better guide to the economic burden than the identity of the party listed on the customs declaration. Charges can also pass through multiple 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 the cost across grades, while a power importer could recover it through its trading margin or a bilateral deal.
For large buyers of steel and aluminium, practical issues include emissions pricing, facility verification, contractual indemnities and financing certificate purchases. Producers with verifiably lower emissions or specialist specifications may be better able to defend margins, while commodity sellers facing intense competition may be pressed to absorb costs. Consumers could also face higher prices without having a direct CBAM registration obligation.
Certificate prices and reporting deadlines
The published EU CBAM certificate price was 82.32 euros per tonne in the third quarter of 2026, up from 75.36 euros in the first quarter. As prices can vary, a static assumption may not match the eventual bill. Applying the full carbon price to every tonne of gross emissions does not replace the applicable legal calculation, which also depends on product emissions, EU free-allocation adjustments and eligible carbon prices 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, potential 2026 exposure falls from 140.2 million euros to 127.3 million euros if the EU fully recognises domestic carbon pricing. That recognition is an assumption, not a legal guarantee, and an importer would need evidence of the qualifying carbon price actually paid for only the allowable amount to be credited.
The annual mass threshold of 50 tonnes excludes many smaller goods importers, but does not apply to electricity or hydrogen. First declarations for goods imported in 2026 are due on 30 September 2027, allowing time to reconcile data but leaving little room for missing factory records. The Finance Ministry projects potential exposure of 161.4 million euros in 2029 as free allowances phase out.
Elevated by CBAM by Clarion Engineer