A Serbian factory buying renewable power and a Serbian wind farm selling electricity to Hungary face different rules under the Carbon Border Adjustment Mechanism (CBAM). The wind farm’s sale is an electricity import subject to the applicable rules and emissions-evidence requirements. A factory using that electricity to make steel, aluminium, cement or fertiliser must instead apply the methodology for its manufactured product.
The distinction matters to an export-oriented economy. Serbia exported approximately EUR 23.7 billion worth of goods in January–August 2026, up 8.8% year on year, and EU member states accounted for 58.3% of Serbia’s total trade with other countries. EU carbon rules can therefore affect investment decisions in Serbian factories even when the electricity they use is not exported.
Applying the electricity-import test to industrial production can produce incorrect conclusions. Under the current framework, purchased electricity does not automatically lower certificate obligations for covered steel and aluminium goods when the applicable calculation addresses direct emissions. Cement and fertiliser may be subject to indirect-emissions treatment under their respective rules. Before assigning a CBAM-related financial benefit to a domestic green power purchase agreement (PPA), an exporter must assess the product classification, production boundaries and precursor materials.
Industrial PPA benefits and contractual claims
Renewable electricity procurement can still serve several commercial purposes without immediately reducing the number of certificates due at the EU border. Long-term PPAs can help Serbian exporters hedge power costs, meet customer procurement requirements and strengthen product-carbon reporting. They can also improve access to sustainability-linked financing and prepare companies for a potential extension of CBAM to downstream products.
Industrial PPAs can meet financing needs on both sides of a transaction. Renewable-energy developers need creditworthy, long-term offtakers to support project financing, while export-oriented manufacturers need predictable electricity costs and stronger low-carbon credentials in EU supply chains. A structured agreement can thus support financing for new Serbian generation capacity while improving the buyer’s competitiveness in export markets.
Contractual claims need to match the buyer’s specific goods and emissions category. A trader or generator promising universal CBAM savings could leave a buyer with a claimed reduction that is not recognised for its Combined Nomenclature (CN) code. Agreements should identify whether they supply electricity, price hedging, Guarantees of Origin (GoOs), metering data, installation-level information or support for product-emissions calculations. The buyer’s technical and legal teams should verify each claimed benefit’s eligibility before giving it a financial value.
Factory evidence and downstream product preparation
Serbian exporters also need systems that connect electricity and emissions records to production. Factories should, at a minimum, reconcile contracted PPA volumes with metered consumption, the relevant production period and electricity allocated to specific products. Where actual electricity-related emissions are legally relevant, supporting records must satisfy the applicable methodology. Even when electricity data does not directly change current CBAM liabilities, it can remain useful to customers and lenders and for future regulatory developments.
A proposed CBAM expansion to downstream steel- and aluminium-intensive products from 2028 adds a further reason to prepare those records. Serbian automotive suppliers, machinery manufacturers, metal fabricators and electrical-equipment producers should begin mapping material inputs and electricity flows rather than wait for the final product list. The scope remains under negotiation, but the policy direction points to closer scrutiny of supply-chain emissions and more extensive data requirements.
For Serbian manufacturers, an industrial electricity strategy increasingly forms part of an export strategy. Alongside negotiating the lowest possible megawatt-hour price, they need to establish what their procurement can demonstrate, who owns its environmental attributes and how electricity is allocated to production. They also need to determine which customer or regulatory claims the evidence can legitimately support. With support from CBAM.Clarion.Engineer.