At its session held on 28 August 2025, the Government of the Republic of Serbia adopted Regulation on Special Conditions for Trade of Certain Types of Goods (hereinafter, the “Regulation”), with its implementation starting on 1 September 2025, and a 6-month validity period.

The Regulation applies to the 23 goods including milk, dairy and mixed products, eggs, bread and pastries, flour; oils and fats; fresh and processed meat and fish; soft drinks, coffee, tea; fresh fruits and vegetables; sugar; home cleaning products; personal hygiene and cosmetic products; kitchen paper and accessories; baby food; and diapers.

Under the Regulation, the margin is limited to 20%, to be applied by retailers that carry out non-specialized retail trade (e.g. supermarkets and department stores), which in 2024 earned a total business income of more than RSD 4,500,000,000, as well as wholesalers that in the last year earned a total business income of more than RSD 4,500,000,000.

According to the Article 4 of the Regulation, the maximum wholesale margin, calculated on the selling price excluding VAT as of 1 August 2025, reduced by rebates, fees and discounts, may not exceed 20%. Also, the invoiced price of the supplier may not exceed the price that was valid on 1 August 2025.

The Regulation also sets certain conditions for the relationship between retailers and suppliers regarding the total amount that a retailer may charge an individual supplier, providing that this amount may not exceed 10% of the total net amount invoiced by the supplier. Additionally, this amount includes all percentage-based and fixed fees and excludes logistics rebates (capped at 3%) and shortages/write-off fees (capped at 1%). If such fees were not contractually agreed upon by 1 August 2025, they may not be introduced or increased. The 10% limit also does not apply to promotional rebates that are fully passed on to the retail price.

The Regulation also prescribes an obligation for retailers to periodically submit price lists to the competent ministry during the validity period thereof. If a legal entity violates the provisions of the Regulation, a fine of RSD 300,000 shall be imposed for each violation, while an amount of RSD 50,000 is provided for the person responsible of the legal entity, with the possibility of a ban from performing certain tasks for that responsible person for a period of six months to one year.