Belgrade, October 28, 2025 – The ESG Working Group of CEBAC, the Council of European Business Associations and Chambers in Serbia, has organized the first of a series of workshops dedicated to CBAM – Carbon Border Adjustment Mechanism. The aim is to help Serbian companies understand how to adapt to the new European regulatory framework, which will come into full effect on January 1, 2026, and will have a direct impact on those exporting to the EU market.
The meeting was opened by Pasquale De Micco, Director of the European Integration and Economy Department at the EU Delegation to Serbia, who took office on October 1. Coming from the European Commission’s Directorate-General for Trade, De Micco shared the European perspective on the new economic security policy and global trade reform.
What is CBAM and Why Does It Affect Serbia
The Carbon Border Adjustment Mechanism is the tool with which the European Union introduces a price on CO₂ emissions incorporated into certain imported products. The basic idea is simple: to ensure that the cost of carbon is aligned between what is produced within the EU, already subject to the European ETS, and what comes from third countries. In other words, to prevent producers in less regulated contexts from competing solely because they do not internalize the environmental cost of their emissions.
For Serbia, this transition is particularly delicate. The country does not yet have a fully operational ETS system and, at the same time, a significant portion of its exports are directed towards European customers. Many local supply chains are also active in carbon-intensive sectors. If the issue is underestimated, there is a risk that Serbian products will be perceived as more “carbon intensive” and therefore less competitive.
The Industries Primarily Affected by CBAM from January 1, 2026
The CEBAC workshop was a reminder that, in the initial phase of implementation, the CBAM will mainly cover these sectors:
- Iron and steel
- Aluminum
- Cement
- Fertilizers
- Hydrogen
- Electricity
New Requirements for Importers and Exporters
With the implementation of CBAM, European importers will be required to purchase CBAM certificates covering the emissions embedded in imported products. The price of these certificates will be linked to the weekly average value of the European ETS. Each year, by May 31, importers will have to submit a CBAM declaration indicating the number of certificates corresponding to the actual emissions of the products purchased during the previous year.
Serbian exporters, in turn, will have to provide their European partners with complete data on embedded emissions, including:
- quantities and customs codes (CN);
- direct CO₂ emissions from the production process;
- indirect emissions from electricity consumption;
- detailed description of the production process.
If such data is not available, EU importers will be forced to use higher default values, making Serbian products less competitive because they are considered more carbon intensive.
Serbia, which has not yet established its own national emissions trading system (ETS), is particularly exposed to CBAM measures, especially in the steel, aluminum, cement, and electricity sectors.
The “De minimis” Threshold and Exemptions
An important development that emerged from the workshop concerns the “de minimis” threshold provided for in the European Commission’s new Omnibus I package:
- imports of up to 50 tons per year per importer will be exempt from CBAM obligations;
- despite the exemption for small volumes, the Commission estimates that it will still cover around 99% of total emissions;
- some categories remain excluded from the exemption, in particular electricity and hydrogen.
This means that only a relatively small part of trade flows will fall within the convenience threshold: for the majority of companies exporting significant volumes, the CBAM will still be fully applicable.
Between Risks and Opportunities: Where Competitiveness Comes into Play
Based on the discussion which emerged during the CEBAC workshop, it is clear that some European operators who import from Serbia are not yet fully aware of the impact of CBAM. This creates a twofold risk. On the one hand, there is the risk of non-compliant behavior, such as incomplete declarations, unreliable data, and delays in compliance. On the other hand, there is the competitive risk: in the absence of accurate information, Serbian products could be classified as more emissions-intensive and therefore penalized compared to alternatives considered more “green.”
At the same time, however, the new scenario opens up a window of opportunity. Companies that start now to measure and reduce their emissions, set up data collection systems, and engage proactively with EU customers can present themselves as reliable, transparent partners that are aligned with ESG criteria. In a market where sustainability is increasingly influencing purchasing decisions, this ability becomes a real differentiator.
How to Prepare for CBAM: Recommended Steps for Serbian Companies
During the workshop, some key recommendations for Serbian companies were shared. Translated into an operational roadmap, we can summarize them as follows:
- Closely follow legislative developments and regulations in real time
- Train local staff and suppliers on CBAM requirements
- Actively coordinate with EU customers
The Role of Roncucci&Partners
The CBAM represents a paradigm shift: it links sustainability, industrial strategy, and access to international markets even more closely. For Serbian companies exporting to the European Union, it is no longer enough to be competitive only in terms of price and quality; it is also crucial to demonstrate conscious management of their emissions.
Roncucci&Partners supports companies in all phases of this process: from analyzing the impact of CBAM on their business model, to designing audit-ready data collection systems, to defining improvement plans that transform regulatory compliance into a concrete competitive advantage.
If your company exports to the EU and operates in one of the sectors concerned, now is the time to take action. Contact us to assess your level of preparedness for CBAM and work with us to build a tailor-made strategy for the European market.
