With the full entry into force of the Carbon Border Adjustment Mechanism (“CBAM”) as of 2026, the export of Serbian products such as steel, aluminium, cement, fertilizers, and electricity will be subject to additional charges. In order to reduce the costs associated with the implementation of the CBAM mechanism, increase the competitiveness of domestic industry under the new conditions, align with European climate policies, and encourage cleaner production, draft versions of the Law on the Greenhouse Gas Emissions Tax and the Law on the Tax on the Import of Carbon-Intensive Products have been prepared.

The Draft Law on Greenhouse Gas (GHG) Emissions Tax introduces a tax on domestic GHG emissions for legal entities and entrepreneurs holding a GHG emission permit, in accordance with climate change regulations, and whose activities include the production of one or more of the following: fertilizers, cement, iron, aluminium, and electricity.

The tax base is defined as the difference between total emitted and reference (technologically unavoidable) emissions. The draft also provides for a tax credit under certain conditions for entities engaged in electricity production, as well as incentives for decarbonization.

On the other hand, the Draft Law on the Tax on the Import of Carbon-Intensive Products introduces a tax on the import of goods that are significant sources of carbon dioxide emissions in their production process, specifically: iron and steel, cement, fertilizers, and aluminium. The taxpayer is the importer of carbon-intensive products, except for those who import less than five tons of such products during the year.

The tax base is determined on the basis of the actual (or validator-estimated) amount of GHG emissions, reduced by the reference amount of emissions. The draft provides for a tax credit equal to the amount already paid for the production of the carbon-intensive product in the country of origin.

Both draft laws establish a tax rate of four euros per ton of carbon dioxide (or carbon dioxide equivalent for other GHGs), calculated in dinar equivalent per the median exchange rate of the National Bank of Serbia on the date of filing the tax return. The deadline for submitting the tax return is 31 May of the current year for the previous year, and the tax period is the calendar year.

The planned start of implementation for both laws is 1 January 2026, while the deadline for adopting the relevant by-laws is 180 days from the date the laws enter into force.