Serbia’s estimated exposure to the European Union’s Carbon Border Adjustment Mechanism (CBAM), an emissions-based import regime, was 140.2 million euros in the Ministry of Finance’s 2026 baseline assessment. Iron and steel accounted for the largest estimated cost, while electricity added 21.8 million euros and faces different compliance rules from metals.
EU import-value figures for 2025 show steel and aluminium were the leading commercial categories among CBAM-coded goods. Steel imports were valued at 60.95 billion euros and aluminium at 30.34 billion euros, out of 111.23 billion euros for all CBAM-coded imports. Together, the metals represented 91.29 billion euros, or about 82.1% of the total.
That EU-wide share covers imports from all non-EU origins, including exempt suppliers; it is not the proportion of Serbian exports covered by CBAM. Serbia’s Ministry of Finance estimated that more than 12% of the country’s exports to the EU fall within scope.
Serbia’s exposure spans metals and electricity
In the 2026 baseline, the Ministry estimated exposure of 89.1 million euros for iron and steel, 19.5 million euros for aluminium and 21.8 million euros for electricity. Cement and fertilisers accounted for the remainder. Steel producers carry the largest estimated cost, while electricity is also an important part of Serbia’s trade with the EU.
Trade-composition figures for 2024 offer a separate measure of Serbia’s exposure. Steel represented 4.5 percentage points of exports to the EU, aluminium 2.0 points and electricity 4.7 points, giving a CBAM-related export share of approximately 11.7%. Metals made up roughly 56% of that covered export share.
The Serbian figures are based on 2024 trade, while the EU import values are for 2025 and use a different denominator; the shares should not be treated as interchangeable annual rankings. A one-size-fits-all approach would also overlook the difference between a coated-steel coil sold to a processor and a megawatt-hour of Serbian electricity entering Hungary’s power system.
Plant emissions and product codes shape compliance
For covered steel items, the CBAM charge is not a simple carbon surcharge on invoice value. It depends on a plant’s direct process emissions, verified production route, eligible input materials and the EU free-allocation adjustment. Importers may use regulatory default values when actual emissions data are unavailable. Serbia’s Ministry of Finance warned that those factors may exceed actual domestic emissions in some cases, potentially disadvantaging lower-emission plants that cannot substantiate their performance.
The initial 2026 emissions scope for covered aluminium products focuses on direct emissions. Producers may nonetheless face commercial pressure to disclose electricity sources and indirect footprints for customers’ decarbonisation strategies. A buyer’s contractual preference for low-carbon electricity may go beyond the electricity emissions included in the legal CBAM certificate calculation, so 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. Their ability to retain customers depends on actual emissions, data assurance and product economics for the relevant CN8 code, rather than the EU-wide metals share alone. The immediate policy priorities identified for Serbia are a credible plant-level steel emissions baseline, accurate mapping of mill products to EU customs codes and separate treatment of electricity trade.
Elevated by CBAM.Clarion Engineer