Serbia’s estimated exposure to the EU Carbon Border Adjustment Mechanism (CBAM) was €140.2 million in the Ministry of Finance’s 2026 baseline assessment. Iron and steel accounted for the largest share, while electricity added €21.8 million. The exposure profile differs from the EU-wide import mix and calls for a separate approach to compliance.
In the Serbian baseline, estimated exposure was €89.1 million for iron and steel, €19.5 million for aluminium and €21.8 million for electricity. Cement and fertilisers accounted for the remainder. Steel producers face the largest estimated cost, but electricity is also a significant part of Serbia’s trade with the EU.
Based on 2024 trade, steel accounted for 4.5 percentage points of Serbian exports to the EU, aluminium for 2.0 points and electricity for 4.7 points. Together, these categories represented approximately 11.7% of exports, with metals making up roughly 56% of that CBAM-related share. The Ministry of Finance estimated separately that more than 12% of Serbia’s exports to the EU fall within CBAM scope.
EU import values show a different product mix
Steel and aluminium were the largest commercial categories among EU imports of CBAM-coded goods in 2025. Steel imports were valued at €60.95 billion and aluminium imports at €30.34 billion, out of total imports of €111.23 billion. The two metals together accounted for €91.29 billion, or about 82.1% of the total.
The 82.1% figure measures imports from all non-EU origins, including exempt suppliers; it does not represent the share of Serbian exports covered by CBAM. The EU import figures and Serbia’s export shares also refer to different years and use different denominators, so they are not interchangeable rankings. They reflect distinct trade flows, such as a coated-steel coil sold to a processor and a megawatt-hour of Serbian electricity entering Hungary’s power system.
Plant data and product codes determine compliance
For covered steel products, the charge is not a simple carbon surcharge based on invoice value. It depends on a plant’s direct process emissions, its verified production route, eligible input materials and the EU free-allocation adjustment. Where actual emissions data are unavailable, importers may use regulatory default values.
Serbia’s Ministry of Finance warned that default factors may exceed actual domestic emissions in some cases, potentially disadvantaging lower-emission plants that cannot substantiate their performance. Under the current CBAM framework, aluminium’s initial emissions scope applies in 2026 and covers direct emissions. Producers may still face commercial pressure from customers to disclose electricity sourcing and indirect footprints for decarbonisation strategies.
A buyer’s preference for low-carbon electricity can extend beyond the emissions included in the legal certificate calculation, and the two should not be conflated in pricing. Serbian producers compete with suppliers from China, Türkiye and India, as well as lower-carbon plants inside the EU. Retaining customers depends on actual emissions, data assurance and product economics for the relevant CN8 customs code, rather than the EU-wide metals share alone.
Serbia’s immediate priorities are to establish a credible plant-level steel emissions baseline, map mill products accurately to EU customs codes and handle electricity trade separately.
Elevated by CBAM by Clarion Engineer