Serbia’s Finance Ministry estimated potential exposure of 140.2 million euros in 2026 under the European Union’s Carbon Border Adjustment Mechanism (CBAM), while Serbian suppliers may bear part of the economic cost through contract pricing and lower sale prices. EU importers are legally responsible for declaring embedded emissions and surrendering CBAM certificates, but the party with that legal duty is not necessarily the party that ultimately bears the cost.
The EU framework assigns authorisation, emissions reporting and certificate surrender to the importer or an eligible indirect customs representative. The Finance Ministry’s indicative scenario used 2025 export volumes, default emissions factors and a carbon reference price of 75.36 euros per tonne.
Iron and steel accounted for 89.1 million euros of the estimated 2026 exposure, according to the ministry. Its breakdown also included 21.8 million euros for electricity, 19.5 million euros for aluminium, 7.8 million euros for fertilisers and 1.9 million euros for cement. The ministry described the estimates as indicative scenarios.
Contract terms determine cost pass-through
An EU importer may use contract terms to transfer some or all of the expected CBAM cost to a Serbian supplier, seek verified emissions data to avoid expensive default values, or incorporate the cost into its resale price. When a buyer has strong negotiating power or access to alternative European supply, a Serbian producer may face a lower net ex-works price.
The contract pricing formula is a better indicator of who ultimately bears CBAM costs than the identity of the party named on the customs declaration. Costs can pass beyond the first importer through supply chains, be spread across product grades, or be recovered through wholesale trading margins and bilateral supply contracts.
Examples of possible pass-through include a Polish steel service centre passing a charge to a metal fabricator that supplies a German machine maker, and an aluminium distributor spreading a charge across several product grades. A power importer could recover a charge through a wholesale trading margin or bilateral supply contract.
For large steel and aluminium buyers, practical concerns include emissions pricing, facility verification, contractual indemnities and funding certificate purchases. Producers with both verifiably lower emissions and specialist specifications may defend their margins, while commodity sellers facing intense competition may be pressured to absorb costs. Final consumers may face higher prices even without a direct CBAM registration obligation.
The eventual economic burden also depends on bargaining conditions, certificate prices, product-specific emissions calculations, EU free-allocation adjustments and eligible carbon prices already paid in the producing country. These factors, alongside contract pricing, shape how costs are divided between importers, suppliers and later buyers.
Certificate prices, domestic carbon tax and deadlines
The EU’s published CBAM certificate price was 82.32 euros per tonne in the third quarter of 2026, compared with 75.36 euros per tonne in the first quarter. Because prices can vary, static price assumptions are risky; multiplying the full carbon price by every tonne of gross emissions is not a substitute for the applicable legal calculation.
Serbia introduced a national greenhouse-gas emissions tax in January 2026 with a stated headline rate of 4 euros per tonne of CO2-equivalent. The Finance Ministry modeled 2026 CBAM exposure falling from 140.2 million euros to 127.3 million euros if the EU fully recognised domestic carbon pricing.
That recognition was an assumption in the ministry’s model, not a legal guarantee. An importer would need evidence of the qualifying carbon price actually paid, and only the allowable amount could be credited. The annual mass threshold of 50 tonnes excludes many smaller goods importers from CBAM, but does not apply to electricity or hydrogen.
First declarations for goods imported in 2026 are due on 30 September 2027. The deadline leaves time for data reconciliation but little room for missing factory records. As free allowances phase out, the Finance Ministry projects potential exposure of 161.4 million euros in 2029.
Elevated by CBAM.Clarion Engineer