CBAM Compliance for SEE Manufacturers and Exporters

The EU Carbon Border Adjustment Mechanism (CBAM) is moving out of its transitional reporting phase and toward full application from 2026. For manufacturers and exporters in Southeast Europe — particularly in iron, steel, aluminium, cement, fertilisers, electricity, and hydrogen — the financial and administrative impact is becoming material.

Non-EU producers (including those in Serbia, Montenegro, Bosnia and Herzegovina, and North Macedonia) do not pay CBAM directly. The obligation sits with EU importers. However, buyers in the EU increasingly require embedded-emissions data from suppliers as part of their own CBAM declarations, and that data requirement is now propagating through supply chains.

Slovenian and Croatian producers, as EU-based entities, remain outside the scope of CBAM as declarants but may still face it as importers of affected inputs from non-EU jurisdictions. Groups with mixed EU and non-EU operations therefore need coordinated data collection and a common emissions accounting methodology.

Practical readiness includes mapping in-scope product lines, establishing a verifiable emissions data process aligned with the EU methodology, and engaging early with EU customers on their CBAM data requests. Waiting until 2026 to respond to customer data requests creates real commercial risk.