The EU’s Carbon Border Adjustment Mechanism is shifting from reporting to financial exposure, with the definitive regime starting on 1 January 2026. EU importers of covered goods must use an authorised CBAM declarant, report embedded emissions, and surrender CBAM certificates linked to the EU ETS price. Any eligible carbon price paid during production can be deducted. The European Commission’s first quarterly CBAM certificate price for Q1 2026 was €75.36/tCO₂e.
For Serbia, the policy focus is tied to the scale of metals trade with the EU. In 2025, EU imports from Serbia included around €599 million of iron and steel and €863 million of non-ferrous metals. EU exports to Serbia also included substantial metal flows. This creates a supply-chain compliance situation where Turkish, Serbian and EU data need to connect.
Serbian producers face different carbon profiles across steel and aluminium
Serbian industrial capacity is split across producers with different carbon profiles. HBIS Serbia in Smederevo operates an integrated steel platform with around 2.2 million tonnes/year capacity, producing flat-steel products including hot-rolled coil, cold-rolled coil, pickled coil and tinplate. Metalfer is positioned around scrap-based steelmaking and long products, with its own rebar, coil and wire-rod chain. Impol Seval is Serbia’s major rolled-aluminium platform, producing aluminium rolled materials for international customers and investing in furnace modernisation to reduce gas and energy use.
The CBAM implications extend beyond Serbian production steps when Turkish-origin inputs are used. For Serbian steel and aluminium exports into the EU, Turkish raw-material suppliers are treated as part of the CBAM evidence chain rather than only procurement links. The practical requirement is whether a Serbian exporter can prove embedded emissions for each product and batch after transformation in Serbia.
Turkish supplier data becomes part of Serbian exporters’ CBAM file
The Turkish supplier universe functions as a screening map until documentation confirms the connection for each shipment. For Serbian steel producers and processors, relevant Turkish counterparties include flat-steel and coated-steel suppliers such as Erdemir, with product ranges covering hot-rolled, cold-rolled, galvanised and tin/chrome-coated flat products. Long-product or semi-finished suppliers such as Kardemir Çelik describe chains covering steelmaking, billets, profiles, rebar and wire rod.
For Serbian aluminium processors and exporters, the Turkish supplier map includes primary and downstream aluminium producers. Eti Alüminyum is relevant on the primary side with capacity across bauxite processing, alumina and cast aluminium products. Assan Alüminyum covers flat-rolled aluminium including coil, sheet, foil and pre-painted products, with declared installed capacity up to 360,000 tonnes and export activity across more than 70 countries. ASAŞ is relevant for extrusions, flat-rolled products and aluminium systems, while Teknik Alüminyum supplies coil, sheet and strip products across common alloy groups.
EU importer declarations rely on CN-code-based evidence from Serbian exporters
The EU importer remains responsible for the CBAM declaration when Serbian-origin goods enter the EU. The Serbian exporter must provide the evidence required for that declaration. When Turkish steel or aluminium is used as a precursor or input in Serbia, plant-level emissions data from the Turkish supplier—along with production route, energy data and product classification—becomes part of the evidence file maintained by the Serbian exporter.
A Turkish input does not automatically create a separate CBAM charge unless it is imported into the EU directly. However, its embedded emissions can be incorporated into the embedded-emissions calculation for the Serbian product sold into the EU. The key dividing line for classification is the CN code, since CBAM mapping depends on customs classification rather than broad commercial descriptions such as “steel input” or “aluminium raw material.”
Steel inputs require product-route details; scrap shares must be documented
For steel exports from Serbia using Turkish inputs, exporters need to identify whether inputs correspond to billet, slab, hot-rolled coil, cold-rolled coil, coated sheet, wire rod, bar, tube, fastener material or another covered product category. The methodology also requires data including scrap share, alloying content and precursor emissions. Ferrous waste and scrap are treated differently from steel products under CBAM methodology.
A scrap-based chain can therefore produce a different CBAM profile compared with blast-furnace or high-primary-material routes. Even where scrap-based claims are made, documentation is required rather than relying on assertions about scrap content.
Aluminium coverage includes primary and secondary distinctions; scrap is excluded
For aluminium inputs used in Serbia before export to the EU, coverage extends to unwrought aluminium categories including powders, bars, rods, profiles and wire. It also includes plates, sheets, strip and foil categories as well as tubes and pipe fittings alongside several downstream aluminium goods within scope. Aluminium scrap is excluded from coverage under the described methodology.
The approach distinguishes between primary and secondary aluminium production routes. It requires attention to direct emissions as well as indirect emissions during the transitional phase. For some aluminium production pathways it also involves process emissions such as PFCs.
Minimum procurement documentation links Turkish plants to Serbian batches
A minimum procurement file for a Serbian exporter buying from Turkey should include supplier name and plant name alongside CN code details. It should also cover non-preferential origin information plus batch or heat number references supported by mill certificates. Product weight and production route are required along with direct emissions expressed in tCO₂e/t.
The file should further include precursor emissions plus electricity consumption and an emission factor used in calculations. Scrap share documentation and alloy composition are required where relevant to the product chain. It should also include any carbon price paid during production and confirmation that data can withstand third-party verification.
Turkey’s climate policy direction intersects with MRV expectations for suppliers
The compliance chain creates commercial risk if evidence quality varies across inputs used in production exported to the EU. An EU buyer may price Serbian metal exports based on the weakest part of the evidence chain when embedded-emissions data cannot be verified at plant level for Turkish inputs used in Serbia.
Toward that same direction on measurement expectations, Türkiye adopted its first Climate Law in July 2025 establishing a legal basis for a national emissions trading system. Its ETS pilot phase is expected to start in 2026. While this does not remove CBAM exposure automatically for Turkish suppliers exporting into supply chains feeding EU markets, it increases pressure for EU-compatible MRV data.
Downstream expansion could extend CBAM exposure beyond primary materials
The next pressure point identified is expansion beyond primary steel and aluminium goods into more processed items. The EU has signalled movement toward extending CBAM to certain downstream goods while strengthening anti-circumvention rules. This matters for Serbian exporters because exposure may not stop at primary steel or aluminium or simple semi-finished products.
The risk profile may increase for more processed goods, assemblies and metal-intensive products where production could be shifted just outside the bloc to avoid carbon costs as perceived by EU authorities.
Serbian exporters’ procurement shifts toward CBAM-qualified supplier evidence
The operational requirement described for Serbian producers involves moving from normal procurement toward CBAM-qualified procurement. HBIS Serbia, Metalfer, Impol Seval and downstream exporters using Turkish inputs are described as needing supplier selection criteria that include readiness of CBAM data rather than focusing only on price, delivery terms or alloy quality.
Supplier selection should incorporate installation-level emissions information plus verification discipline and precursor traceability so that repeatable evidence can be provided for each shipment exported into the EU under an importer declaration process.
The suppliers expected to perform in this environment are those able to provide bankable emissions data alongside metal supply such as coil or billet categories referenced in the supplier descriptions. Exporters expected to protect access are those able to show a clean chain from Turkish raw material through Serbian processing plant documentation to EU importer declaration alignment on carbon cost, product origin and embedded-emissions evidence before shipment reaches the border.
Elevated by CBAM.Clarion.Engineer