EU imports from Serbia in 2025 included about $640.7 million of iron and steel under HS Chapter 72 and another $573.5 million of articles of iron or steel under Chapter 73, for a gross envelope of roughly $1.21 billion. A large majority of Serbia’s main steel exports, including hot-rolled, cold-rolled and coated flat products as well as downstream structures, tubes and fasteners, falls within the current carbon-border perimeter. EU data used in a new steel safeguard framework show imports of the concerned steel products rising from 657,318 tonnes in 2024 to 760,234 tonnes in 2025.
CBAM coverage alongside rising safeguard volumes
CBAM does not apply to all goods in the broad HS72-plus-HS73 trade envelope. Coverage depends on specified CN codes rather than general product labels, with exclusions including ferrous waste and scrap under HS 7204 and specified ferro-alloys. Chapter 73 is described as more selective, with some downstream product families explicitly covered while others are not. A first-pass mapping of Serbia’s 2025 trade suggests around €960 million of the roughly €1.07 billion broad HS72-plus-HS73 envelope falls clearly inside current CBAM headings.
The same EU datasets used for safeguards show imports of the steel products concerned from Serbia at 664,743 tonnes in 2023, 657,318 tonnes in 2024 and 760,234 tonnes in 2025. The EU described the increase over 2023-2025 as 14%, with the jump between 2024 and 2025 at about 15.7%. In August, 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. The safeguard product basket is not identical to the CBAM product basket.
Smederevo supply chain exposure extends beyond blast furnace operators
HBIS Group Serbia is described as the country’s dominant primary steel producer, with its Smederevo steelworks positioned at the start of a supply chain reaching processors, fabricators, construction-product manufacturers, machinery suppliers and exporters. Treating CBAM only as an HBIS issue is described as incomplete because CBAM exposure can begin upstream at the steel mill even when downstream exporters do not operate blast furnaces or produce crude steel. For downstream manufacturers, emissions incorporated in qualifying precursor materials can become central to emissions assigned to the final CBAM good.
EU imports from Serbia under Chapter 73 alone were worth more than $570 million in 2025. Among the largest lines were approximately $209 million of steel structures and structural parts, almost $147 million of other iron and steel articles, around $40 million of tubes and hollow profiles, and more than $26 million of screws, bolts and related fasteners. The carbon file is described as following the material used in production inputs rather than being limited to direct emissions at a final exporter’s site.
Installation-level evidence requirements for embedded emissions
The data needed for actual emissions provided to an EU customer is described as no longer a general ESG estimate. Calculations must be linked to a defined installation, production process and reporting period. The evidence file is described as requiring controlled inputs including installation identity and boundaries, production route, fuel consumption and process emissions, material and energy balances, production volumes and precursor quantities.
The same file is also described as needing embedded emissions of relevant precursors, allocation methodology, metering and laboratory records, monitoring plan and calculation files with data controls. Product quantities and CN classification are required alongside linkage between the EU customer and authorised declarant. Where actual values are used, independent verification is required.
Definitive-period default values raise incentives for verified data
A structure producer buying coil, plate or tube for export-facing transformation must address additional questions under CBAM related to which installation produced precursor inputs and what production route was used. The calculation also depends on whether specific embedded emissions are based on actual verified data or default values, along with purchased quantities and how much is allocated to exported products. Consumption must be reconciled with stock movements, scrap, yield and production records.
If suppliers cannot provide usable information, EU importers may rely on default values that are described as deliberately conservative under the definitive-period system. For iron and steel and aluminium, applicable default values carry a 10% mark-up in 2026, rising to 20% in 2027 and 30% from 2028. The certificate approach is described as creating progressively stronger commercial incentives to develop verified actual emissions where those values are competitive.
Renewable electricity does not remove direct embedded-emissions liability
The role of renewable electricity is described as needing careful treatment within current definitive CBAM scope for iron and steel. Steel producers worldwide are signing renewable PPAs and building on-site solar plants to reduce energy costs and carbon footprints. Investments are described as potentially reducing corporate emissions and supporting future decarbonisation.
The source states that under current definitive CBAM scope iron and steel are subject to direct embedded emissions rather than indirect electricity emissions. As a result, buying renewable electricity does not automatically remove immediate CBAM liability associated with direct steelmaking emissions for blast-furnace/basic-oxygen-furnace routes. It also notes that HBIS has pursued renewable-energy initiatives at its Smederevo site including planning for solar generation.
€75/tCO₂ certificate pricing links carbon data to import economics
The EU’s CBAM certificate price is linked to EU ETS auction prices published by the European Commission. A Q1 2026 CBAM certificate price of €75.36 per tonne of CO₂ was published alongside a Q2 price of €75.28 per tonne of CO₂. The source states that the cost attached to a tonne of Serbian steel cannot be calculated by multiplying gross plant emissions by €75 alone because final figures depend on relevant embedded emissions.
The final number is described as depending on benchmark or free-allocation adjustments under CBAM rules plus any recognised carbon price already effectively paid and other regulatory parameters. At around €75/tCO₂, relatively small differences in verified embedded emissions can translate into meaningful differences across hundreds of thousands of tonnes according to the source framing. Emissions data is therefore described as commercially material rather than limited to sustainability reporting.
Contract clauses shift evidence risk ahead of annual declarations
The next stage is described as moving into commercial contracts where EU buyers may demand more specific CBAM provisions from non-EU suppliers. Clauses can cover data-delivery deadlines, verification rights, access to installation information, accuracy warranties and treatment of default values including precursor data allocation methodology. The source also lists liability where incorrect data increases buyer CBAM cost alongside cooperation with an accredited verifier.
The first annual CBAM declaration covering 2026 imports is due by Sept. 30, 2027. Where actual emissions are used those values must be verified under definitive-period guidance published by the European Commission on Aug. 14 for steel guidance (Guidance 5d), followed by verification and accreditation guidance later that month. For Serbia’s industry this timing implies that 2026 production data already matters because meters may not align with production boundaries and precursor documentation may be missing if evidence preparation starts late.
Bottlenecks concentrate on precursor documentation upstream of exported goods
The source describes integrated production as placing much required information inside a single industrial system while downstream processing can require upstream cooperation for precursor embedded-emissions calculations. A manufacturer cannot calculate accurate embedded emissions for a complex CBAM good if it does not know emissions associated with precursor material entering its plant. It also states that this shifts purchasing departments into part of carbon-control systems for exporters.
The evidence-building approach is described as increasingly focused on creating an audit-ready file during production rather than after the reporting year ends because production batches and exported shipments may be difficult to allocate retrospectively if documentation gaps appear later.
Safeguards add another constraint alongside carbon compliance
A Serbian producer may need to manage tariff-rate or safeguard constraints alongside product origin requirements tied to EU customer demand plus carbon data needs linked to CBAM certificate pricing. The source describes this combination as giving Serbia’s steel industry a broader challenge than calculating emissions alone because market access must be protected while reducing carbon costs associated with that access.
The domestic backdrop is also described using Serbian industrial production figures showing basic metals output down 12.5%