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CBAM in Serbia: two carbon prices, one data problem.

Since 1 January 2026, Serbian exporters answer to two carbon systems at once: the EU's CBAM, now in its definitive regime and declared by your EU customers, and Serbia's own carbon tax, in force since the very same day. This guide covers what Regulation (EU) 2023/956 really asks of a Serbian producer, the dates that matter, and the numbers your buyer needs from you.

Since 1 January 2026

Serbian exporters sit between two carbon systems.

The CBAM transitional period (October 2023 – December 2025) is over. More than 60% of Western Balkan goods exports go to the EU, which makes the region one of the most CBAM-exposed in the world — and 1 January 2026 brought three changes at once.

EU CBAM — definitive regime

Your EU customers now declare the embedded emissions of the cement, iron and steel, aluminium, fertilisers, electricity and hydrogen they import from Serbia, and surrender CBAM certificates against them.

Serbia's EUR 4 carbon tax

A national tax on greenhouse-gas emissions — EUR 4 per tonne — applies to industrial operators holding emissions permits, in force since 1 January 2026.

Serbia's import levy

A border levy on carbon-intensive imports mirrors the EU CBAM product list (electricity excluded for now) and is planned to rise annually toward EU ETS price parity by 2034.

The EU-side legal duty sits on your customer, the authorised CBAM declarant — but Regulation (EU) 2023/956 defines exactly which installation-level data they must collect from you. That is why the request lands in your inbox, and why it is not optional goodwill.

The legal line

Who actually owes what?

The CBAM obligation — authorisation, the annual declaration, buying and surrendering certificates — belongs to the EU importer. So do the penalties: EUR 100 per tonne of CO2e at base, and three to five times that for importing CBAM goods without authorised-declarant status. None of that can be enforced against a Serbian company.

Your role is defined just as precisely. As a non-EU operator of an installation, you supply installation-level embedded-emissions data through the European Commission's free communication template for installations, and you can register in the operator module of the CBAM Registry to share that data with every declarant who buys from you — once, instead of once per customer.

If you send nothing, your customer does not simply give up. Since the 2025 simplification regulation they may fall back on the Commission's default values under Implementing Regulation (EU) 2025/2621 — but a mark-up applies when defaults replace actual data: 10% for 2026 imports, 20% for 2027 and 30% from 2028. Your goods are then declared dirtier than they probably are, and cost more than a competitor's who provided verified numbers. That is the real commercial pressure on Serbian steel, aluminium, cement and fertiliser producers.

Timeline

CBAM Serbia: the dates that matter.

DateWhat happens
1 Oct 2023 – 31 Dec 2025Transitional period — quarterly reporting only. Closed.
1 January 2026CBAM definitive regime applies. Serbia's EUR 4/t emissions tax and its border levy on carbon-intensive imports enter into force the same day.
7 April 2026First quarterly CBAM certificate price published for Q1 2026: EUR 75.36, derived from EU ETS auction prices.
1 February 2027CBAM certificate sales open on the central platform, retroactively covering the 2026 import year.
30 September 2027First annual CBAM declaration due, and certificates for 2026 imports surrendered, by the EU declarant.

Dates per Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083; the Q1 2026 certificate price per the European Commission's CBAM price page.

No Article 9 deduction — yet

There is no EU decision recognising Serbia's EUR 4 per tonne tax for a CBAM Article 9 deduction, and the Article 9 implementing act was still a draft as of late 2026. Treat every "our local tax offsets CBAM" claim as unconfirmed until the act and a scheme-specific recognition exist. We track the state of play on our Article 9 carbon-price deduction page.

Data, not panic

One dataset serves every request.

Most Serbian exporters do not need a lawyer in Brussels. They need installation-level numbers their customers can legally declare, and a process that repeats every year without drama.

We set that up once: a monitoring approach, country-specific emission factors, the Commission's communication template and registry access to share it. The software behind it is Karbon360°, our own ClimateTech platform.

Karbon360° dashboard showing a company greenhouse-gas inventory
Climate technology built in Kosovo

Karbon360°

Karbon360° transforms energy and production data into structured, GHG Protocol-based greenhouse-gas inventories — the same numbers that feed the CBAM communication template, your buyer's declaration and your company's own carbon footprint.

Scope 1, 2 & 3GHG Protocol inventoriesEmission-factor traceabilityAudit trails
Discover Karbon360° ↗
FAQ

Frequently asked.

Does CBAM apply to Serbian exporters directly?
No. The legal obligation under Regulation (EU) 2023/956 sits on the EU importer — the authorised CBAM declarant — who must declare embedded emissions and surrender certificates. A Serbian producer faces no EU fine — the consequence is commercial: your customer is legally required to declare these numbers, and the regulation determines exactly what they must ask you for.
What is Serbia's carbon tax in 2026?
Two interconnected laws have been in force since 1 January 2026: a national greenhouse-gas emissions tax of EUR 4 per tonne on industrial operators holding emissions permits, and a border levy on carbon-intensive imports that mirrors the EU CBAM product list (electricity excluded for now). The import levy is planned to rise annually toward EU ETS price parity by 2034, and Serbia began drafting a new climate-change law in August 2026 as the basis for an eventual emissions trading system.
Can Serbia's EUR 4 tax be deducted from our customer's CBAM bill?
Not today. Article 9 of the CBAM Regulation allows a deduction for a carbon price effectively paid in the country of origin, but the implementing act was still a draft as of late 2026 and no EU decision recognises the Serbian tax. Keep records of every carbon cost you pay, but do not price any deduction into contracts yet.
What happens if we do not send emissions data to our EU customer?
Your customer may declare using the Commission's default values under Implementing Regulation (EU) 2025/2621 — with a mark-up of 10% for 2026 imports, 20% for 2027 and 30% from 2028. Actual verified emissions carry no mark-up, so real numbers make your goods cheaper to import — which is why EU buyers increasingly make the data a condition of the order.
Does the 50-tonne exemption cover our buyers?
The de-minimis threshold exempts an EU importer whose CBAM goods stay under 50 tonnes net mass per calendar year — counted across all suppliers, not just you. It covers iron and steel, aluminium, fertilisers and cement, and does not apply to electricity or hydrogen. Whether your buyer qualifies depends on their total imports, so ask them before assuming CBAM is off the table.
What about electricity exports from Serbia?
Electricity is a CBAM-covered good, and the 50-tonne mass exemption does not apply to it — every kilowatt-hour an EU buyer imports is in scope. Costs follow CBAM certificate prices, derived from EU ETS auctions — EUR 75.36 for Q1 2026, published 7 April 2026. Serbia's own import levy, by contrast, currently excludes electricity.
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Two carbon systems, one data layer.

Tell us what you export and who buys it. We come back within 48 hours with scope, timeline and a fixed-fee quote in writing.