CBAM implementation is moving from policy design into operational reality, and the reporting mechanics are already reshaping trade relationships across energy-intensive supply chains. In Serbia, industry bodies say roughly 2,400 companies exported goods covered by the Carbon Border Adjustment Mechanism to the European Union over the past year, including 1,400 firms active in the last quarter of 2023. The figures include not only manufacturers but also traders or users of covered products, underscoring how compliance obligations can extend beyond factory gates.
Transition reporting exposes data gaps and registry strain
The Chamber of Commerce and Industry of Serbia says it does not have precise information on how many Serbian entities submitted CBAM reports to EU partners for the first reporting period covering the fourth quarter of 2023. The reason is structural: CBAM is designed primarily as an information exchange system on embedded emissions between exporters outside the EU and EU importers who submit reports. As a result, there is no publicly available centralized national registry of CBAM obligors in Serbia.
Industry representatives also point to operational friction inside the EU’s centralized transitional register. The Chamber of Commerce and Industry of Serbia said technical problems emerged around the deadline for submitting first reports, describing the task as complex because exporters worldwide send reports to EU partners for seven industries while those partners must file within a short window.
Six sectors in scope: steel, aluminium, cement, fertilisers, electricity and hydrogen
CBAM’s initial coverage targets imports from six high-emissions sectors considered at elevated risk of carbon leakage into the EU market. These sectors are electricity, iron and steel, cement, aluminium, fertilisers and hydrogen. Based on preliminary estimates from the Chamber of Commerce and Industry of Serbia, more than 95% of entities facing CBAM-related obligations are concentrated in aluminium, iron and steel.
While large operators may have dedicated compliance teams, smaller firms face a different challenge. The Chamber of Commerce and Industry of Serbia highlights that resource constraints and varying preparedness create particular difficulties for small and medium-sized enterprises in the metal sector—whether they sell directly into the EU market or supply one link in another company’s export chain.
Who reports what during the transitional phase
The transitional period runs from October 1, 2023 to December 31, 2025, with full implementation scheduled to start on January 1, 2026. During this transition, EU importers must report embedded emissions—both direct and indirect—along with the possible carbon price paid in the country of origin to the European Commission for covered goods. Companies outside the EU producing and exporting these goods must monitor and calculate direct and indirect emissions and provide that information to their EU partners.
For this phase specifically, there are no financial adjustments required and no requirement for verification by an accredited verifier. That distinction matters for compliance planning: reporting processes must be built now even though certificate purchases and verified submissions are tied to the definitive phase beginning in 2026.
Embedded emissions calculations: direct plus indirect energy emissions
Serbian companies sending information to EU partners are expected to provide totals for embedded emissions in exported products. The Chamber of Commerce and Industry of Serbia says these figures are calculated or measured per unit of product mass and then scaled according to quantities exported.
Reporting also extends beyond emissions generated during production. The Chamber of Commerce notes that indirect emissions must be accounted for as well—emissions associated with electricity used in production processes and energy used for heating production plants.
Deadlines differ for manufacturers versus importers
Deadlines during transition vary depending on whether an entity is treated as an operator of an installation (manufacturers) or as a CBAM declarant/importer. For installation operators, data collection is organized around a 12-month reporting period intended to capture representative facility operations on an annual basis.
For importers or CBAM declarants, reporting is quarterly during transition. The first quarterly report covers October to December 2023 with a deadline of January 31, 2024; due to technical issues affecting the transitional registry, the European Commission allowed an additional 30 days for declarants encountering technical difficulties. When full implementation begins in 2026, reporting for CBAM declarants shifts to an annual basis.
Methodology choices narrow over time
The Chamber of Commerce and Industry of Serbia says there is no methodology specifically prescribed for companies in Serbia regarding how they should execute reporting steps domestically. However, it notes that during the first year of implementation companies can choose among three approaches until December 31, 2024: full reporting using EU methodology; reporting based on equivalent national systems from third countries; or reporting using default values.
From January 1, 2025 onward, only EU methodology will be accepted. Embedded emissions then must be tracked using either calculation or measurement methods involving continuous measurement of greenhouse gas concentrations relevant to production.
Potential penalties target EU declarants but costs can cascade
Penalty measures under CBAM are envisaged for the CBAM declarant—the importer responsible for submissions into the EU system. The Chamber of Commerce and Industry of Serbia states that fines may range from 10 to 50 euros per ton of unreported emissions if a declarant fails to report total imported quantities of CBAM goods, actual total direct and indirect embedded emissions in those goods, or the carbon price paid in the country of production.
The competent national body in an EU member state may also apply penalties when submissions are missing steps required for compliance or when reports are inaccurate or incomplete. Even though penalties apply formally to importers, the Chamber notes that declarants may seek ways to pass costs back to exporters from third countries or adjust commercial relationships going forward.
Training efforts expand awareness ahead of stricter enforcement
The Chamber of Commerce and Industry of Serbia assesses that awareness about CBAM obligations has risen compared with four months earlier when the regulation came into effect. Since October, it organized six specialized sectoral training sessions focused on aluminium, iron/steel, cement and artificial fertilisers; additional sessions were held in January in response to industry demand.
Beyond sector-specific guidance, training on green economic transformation was delivered across 11 Serbian cities during November and December. Entrepreneurs were exposed to concepts including ESG frameworks, product life cycle analysis, carbon footprinting, greenhouse gas monitoring reporting and verification systems, German supply chain law topics and services offered through the EEN network.
Compliance implications across ETS-linked industrial value chains
The transitional phase requires exporters outside the EU—particularly those supplying electricity-intensive processes feeding cementitious materials, metals production and chemical inputs—to deliver embedded emissions data that EU importers can compile into Commission-facing submissions. With full implementation starting January 1, 2026—when report verification becomes mandatory and CBAM certificates come into play—companies will need stronger measurement discipline aligned with evolving methodology rules from January 1, 2025.
For EU producers operating under existing ETS obligations as well as importers managing cross-border supply contracts, CBAM adds a trade-compliance layer that links carbon accounting directly to market access decisions across cement, steelmaking value chains, aluminium production routes, fertiliser manufacturing inputs and hydrogen-related activities. In practice, industry readiness now depends not only on internal decarbonisation planning but also on whether trading partners can exchange accurate emission data within tight quarterly timelines during transition.