EU imports from Serbia in 2025 included about $640.7 million of iron and steel under HS Chapter 72 and another $573.5 million of articles of iron or steel under Chapter 73, creating a gross trade envelope of roughly $1.21 billion. The goods covered by CBAM do not include the entire trade envelope. A large majority of Serbia’s main steel exports, including hot-rolled, cold-rolled and coated flat products as well as downstream structures, tubes and fasteners, fall within the current carbon-border perimeter.
EU data used in a new steel safeguard framework show imports of the relevant steel products from Serbia rising from 657,318 tonnes in 2024 to 760,234 tonnes in 2025, an increase of almost 16% in one year. The safeguard product basket is not identical to the CBAM product basket. Commercially, the two mechanisms affect the same factory gate. The combined effect is described as a double border test for Serbian exporters.
CBAM coverage and the scale of Serbia’s EU-facing steel flows
The broad value of Serbia’s steel trade should not be treated as direct CBAM exposure because CBAM applies based on specified CN codes rather than general industry labels. Most of Chapter 72 is included, but exclusions exist, including ferrous waste and scrap under HS 7204 outside the current Annex I list and specified ferro-alloys. Chapter 73 is described as more selective, with some downstream product families explicitly covered while others are not.
A first-pass mapping of Serbia’s 2025 trade suggests around €960 million of the roughly €1.07 billion broad HS72-plus-HS73 envelope falls clearly inside current CBAM headings. That would indicate coverage close to 90%, with a final audit-grade total requiring reconciliation at CN8 level. The largest Chapter 72 flows illustrate how CBAM reaches into core export categories rather than marginal products.
EU imports from Serbia in 2025 included around $384 million of hot-rolled flat iron and non-alloy steel, $124 million of coated or plated flat products and $63 million of cold-rolled flat products. Together those three categories accounted for almost $570 million. By comparison, ferrous scrap represented about $25 million, described as a major exclusion.
Smederevo supply chains extend CBAM exposure beyond primary production
The Smederevo steelworks is identified as a starting point for understanding exposure because HBIS Group Serbia is described as the country’s dominant primary steel producer. HBIS Group Serbia is positioned at the centre of a supply chain reaching processors, fabricators, construction-product manufacturers, machinery suppliers and exporters. Treating CBAM only as an HBIS issue is described as incomplete because other export lines also fall within covered product categories.
EU imports from Serbia under Chapter 73 alone were worth more than $570 million in 2025. Among the largest lines were approximately $209 million of steel structures and structural parts, almost $147 million of other iron and steel articles, around $40 million of tubes and hollow profiles, and more than $26 million of screws, bolts and related fasteners.
The source material notes that many Serbian companies exporting such goods do not operate blast furnaces or produce crude steel. In those cases, CBAM exposure can still begin upstream at the steel mill because emissions incorporated in qualifying precursor material can carry through to emissions assigned to the final CBAM good. It describes this as a carbon file that follows the material used by downstream manufacturers.
Safeguard measures add tariff-rate constraints alongside carbon data
The carbon-border shift is occurring as the EU tightens steel trade protection through safeguards. In August, the European Commission adopted rules implementing bilateral safeguard measures for steel products originating in countries with which the EU has free-trade agreements, including Serbia. The Commission analysis cited imports from Serbia at 664,743 tonnes in 2023, 657,318 tonnes in 2024 and 760,234 tonnes in 2025.
The EU described the increase over the 2023-2025 period as 14%, while characterising the jump between 2024 and 2025 as about 15.7%. The source material states that safeguard product coverage is not identical to CBAM coverage and should not be conflated with it. It also notes that producers may need to manage tariff-rate or safeguard constraints together with product origin requirements, EU customer demand conditions and carbon data linked to CBAM certificates.
Evidence requirements for embedded emissions start at installations
The data needed for actual emissions supplied to an EU customer is described as no longer being limited to general ESG estimates. The calculation must be linked to a defined installation, production process and reporting period. The source material lists elements for a controlled evidence file including installation identity and boundaries, production route, fuel consumption and process emissions, material and energy balances and production volumes.
The evidence file described also includes precursor quantities; embedded emissions of relevant precursors; an allocation methodology; metering and laboratory records; a monitoring plan; calculation files and data controls; product quantities and CN classification; and linkage between EU customers and authorised declarants. Where actual values are used, independent verification is required according to the source material.
The source material distinguishes integrated production from downstream processing by noting that much information sits inside a single industrial system for integrated producers. For downstream processing, it states that embedded emissions cannot be calculated accurately for complex CBAM goods if precursor emissions associated with input materials entering a plant are unknown. It describes this as turning purchasing departments into part of carbon-control systems.
Precursor documentation gaps can force reliance on conservative defaults
A structure producer may buy coil, plate, tube or other semi-finished inputs and transform them into exported products. Historically procurement focused on grade, dimensions, chemical properties, certification, price and delivery. Under CBAM requirements described in the source material, additional questions include which installation produced each precursor, which production route was used and what embedded emissions apply.
The source material also lists questions on whether embedded-emissions values are based on actual verified data or default values; what quantity was purchased; how much was allocated to final exported products; and whether consumption reconciles with stock movements, scrap, yield and production records. If suppliers cannot provide usable information, it states that EU importers may have to rely on default values.
The default system is described as deliberately conservative for definitive-period calculations. For iron and steel and aluminium under current rules referenced in the source material, applicable default values carry a 10% mark-up in 2026, rising to 20% in 2027, then 30% from 2028. This is presented as creating stronger commercial incentives to develop verified actual emissions where those values are competitive.
Earnings pressure meets weaker basic metals output in 2026 data
The domestic production backdrop is described as weakening alongside these compliance changes. Serbian industrial production data cited show output in basic metals down 12.5% year on year in January-July 2026, with July alone substantially weaker than a year earlier. At the same time, trade indicators are described as more nuanced.
The National Bank of Serbia said exports from fabricated metal products excluding machinery and equipment increased by 20.8% in January-July and made one of the largest positive contributions to overall Serbian export growth. The source material states these indicators are not contradictory because primary or basic-metal production can weaken while downstream exporters continue performing strongly using existing inventories or imported materials or different product mixes or stronger foreign demand.
CERTIFICATE PRICING AND CONTRACT TERMS FOR DEFINITIVE CBAM STEEL DECLARATIONS
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