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 contributed a further €21.8 million. The electricity component distinguishes Serbia’s exposure from the EU-wide import mix and requires separate compliance treatment.
Across the EU, imports of CBAM-coded goods in 2025 totalled €111.23 billion. Steel imports were valued at €60.95 billion and aluminium imports at €30.34 billion, giving the two metals a combined value of €91.29 billion, or about 82.1% of the total.
That 82.1% reflects imports from all non-EU origins, including exempt suppliers; it does not represent the share of Serbian exports covered by CBAM. Serbia’s Ministry of Finance estimated that more than 12% of the country’s exports to the EU are within the mechanism’s scope.
Serbia’s exposure includes metals and power
In Serbia’s 2026 baseline, iron and steel accounted for €89.1 million of estimated exposure, compared with €19.5 million for aluminium and €21.8 million for electricity. Cement and fertilisers made up the balance of the €140.2 million estimate. Steel producers face the largest estimated cost, but electricity is also a significant part of Serbia’s trade with the EU.
Serbia’s 2024 export composition offers a separate measure of exposure: steel accounted for 4.5 percentage points of exports to the EU, aluminium for 2.0 points and electricity for 4.7 points. Together, these categories represented an approximately 11.7% CBAM-related share of exports. Metals accounted for roughly 56% of that covered export share.
The Serbian export shares and the EU’s 2025 import values use different years and denominators, so they are not interchangeable rankings. A single compliance 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.
Emissions data and customs codes determine compliance
For covered steel products, the CBAM charge is not simply a 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. Where actual emissions data are unavailable, importers may use regulatory default values. Serbia’s Ministry of Finance cautioned that these factors can exceed actual domestic emissions in some cases, potentially penalising 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 their electricity sources and indirect footprints for decarbonisation strategies. Buyers’ preferences for low-carbon electricity can extend beyond emissions included in the legal certificate calculation, and the two should not be conflated in pricing.
Serbian producers compete with suppliers in China, Türkiye and India, as well as lower-carbon plants within the EU. Their ability to retain 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 baseline for steel emissions, map mill products accurately to EU customs codes and handle electricity trade separately.
Elevated by CBAM by Clarion Engineer