Serbia’s ability to compete in export markets is increasingly tied to how electricity evidence is handled under CBAM, with the issue rooted in the country’s trade structure rather than the size of its domestic power market. Serbia exported approximately EUR 23.7 billion worth of goods in January–August 2026, up 8.8% year on year. EU member states accounted for 58.3% of Serbia’s total external trade.
CBAM coverage differs for electricity sales and electricity use in production
A key distinction applies between electricity traded as a CBAM-covered good and electricity used to manufacture another product that is covered by CBAM. Under the framework described, electricity exported from Serbia to an EU market is treated according to the rules for electricity imports and the emissions evidence for that specific transaction. For example, a Serbian wind farm selling electricity to Hungary is subject to the relevant electricity import rules and associated emissions evidence.
By contrast, where a Serbian factory purchases renewable electricity to produce steel, aluminium, cement or fertiliser, the applicable methodology depends on the manufactured product rather than applying electricity-import logic directly. In that situation, exporters need to follow the methodology applicable to the specific product’s CBAM calculation approach. Applying an electricity-import test directly to industrial production can therefore lead to incorrect conclusions.
Certificate effects depend on product rules and production boundaries
The current framework does not automatically remove certificate obligations for covered steel and aluminium goods when electricity is purchased, where the applicable calculation focuses on direct emissions. Cement and fertiliser may be subject to indirect-emissions treatment under their respective CBAM rules. Before an exporter attributes a CBAM-related financial benefit to a domestic green power purchase agreement (PPA), product classification, production boundaries and precursor materials must be assessed.
According to the text, this distinction does not weaken the business case for renewable electricity procurement by industry. Instead, it is presented as enabling a more credible basis for investment decisions, while recognising that immediate certificate reductions at the EU border are not guaranteed.
PPAs can support cost hedging, reporting and financing access
Serbian exporters can use long-term PPAs to hedge electricity costs, meet customer procurement requirements and strengthen product-carbon reporting. The procurement approach is also linked to improving access to sustainability-linked financing and to preparing for possible CBAM expansion to downstream products. The text states that these benefits can retain commercial value even if they do not immediately reduce the number of certificates required at the EU border.
The financing opportunity is described as significant because industrial PPAs can address two investment needs at the same time. Renewable-energy developers require creditworthy, long-term offtakers for project financing, while export-oriented manufacturers need predictable electricity costs and stronger low-carbon credentials within EU supply chains. A well-structured agreement, the text says, can help finance new Serbian generation capacity while improving buyer competitiveness in export markets.
Contracts must be specific and eligibility should be verified
The main risk highlighted is overstating the benefits associated with electricity procurement. If a trader or generator promises universal CBAM savings, the buyer may later find that the claimed reduction is not recognised for its specific Combined Nomenclature (CN) code or emissions category. Contracts, therefore, should specify precisely what is being supplied, including whether it is electricity, price hedging, Guarantees of Origin (GoOs), metering data, installation-level information or inputs for product-emissions calculations.
The buyer’s technical and legal teams should verify the eligibility of each claimed benefit before it is assigned a financial value. The text also emphasises that benefits must be supported by documentation that fits the applicable CBAM methodology and the buyer’s product classification and emissions category.
Evidence management and data mapping for CBAM expansion
Serbian exporters are also described as needing a reliable system for managing emissions and electricity evidence. At minimum, factories should reconcile contracted PPA volumes with metered consumption, the relevant production period and the allocation of electricity to specific products. Where actual electricity-related emissions are legally relevant, supporting records must meet the requirements of the applicable methodology.
Even where electricity data does not directly affect current CBAM liabilities, the text says it can remain valuable for customers, lenders and future regulatory developments. It further points to the proposed expansion of CBAM to downstream steel- and aluminium-intensive products from 2028, which it says raises the importance of preparation.
Implications for Serbian export strategy and supply-chain data
For 2028, the text states that Serbian automotive suppliers, machinery manufacturers, metal fabricators and electrical-equipment producers should begin mapping material inputs and electricity flows rather than waiting for final product lists. Although the scope remains subject to negotiations, the policy direction is described as pointing towards greater scrutiny of supply-chain emissions and more extensive data requirements. In parallel, it frames industrial electricity strategy as increasingly becoming export strategy for Serbia.
Competitive manufacturers, the text says, will need to go beyond negotiating the lowest possible megawatt-hour price. They will also need to determine what electricity procurement can demonstrate, who owns the associated environmental attributes, how electricity is allocated to production and which customer or regulatory claims the supporting evidence can legitimately substantiate.
Supported by CBAM.Clarion.Engineer