Revised Rules on Trade Under Special Conditions – What Businesses Should Know

The amendments to the Decree on Special Conditions for Trade in Certain Goods were published in the Official Gazette of the Republic of Serbia No. 10/2026 of 30 January 2026 and entered into force on 31 January 2026. These amendments intervene in an already existing price-control framework applicable to a range of consumer goods, including food products, household chemicals, personal hygiene items and baby products, which have been subject to temporary market-stabilisation measures.

The original Decree introduced a system of price and margin controls aimed at limiting the impact of inflationary pressures in the retail sector. Its application is time-limited and linked to a six-month period from the start of its implementation in September 2025, with the possibility of further extensions depending on market conditions and regulatory policy decisions.

A central change introduced by the latest amendments is the deletion of the provision that effectively capped suppliers’ invoice prices toward retailers by reference to historical price levels. By removing this rule, the regulator has partially relaxed upstream price formation, allowing suppliers greater commercial flexibility in negotiating supply terms.

At the same time, the core retail price-control mechanisms remain in place. The maximum retail margin continues to be capped at 20% calculated on the net purchase price (excluding VAT), and this limitation applies both to regular and promotional sales. These restrictions primarily affect larger retail operators meeting prescribed financial thresholds.

Wholesale and distribution margins also remain regulated, with reference prices tied to earlier benchmark periods and adjusted for rebates and discounts. In addition, the framework governing various types of fees and charges that retailers may impose on suppliers has not been materially altered, thereby maintaining limits on ancillary commercial burdens in the supply chain.

The Decree continues to impose transparency obligations, including duties related to price lists and the provision of information to competent authorities. These obligations are designed to facilitate regulatory oversight and enable monitoring of compliance across the distribution network.

Non-compliance with the prescribed margin caps, pricing rules or transparency requirements may trigger significant misdemeanour liability for both legal entities and responsible individuals. The enforcement environment therefore remains relevant for operators active in fast-moving consumer goods markets.

For companies engaged in retail, wholesale and distribution, the evolving regulatory framework requires continuous monitoring and, where necessary, adjustments to contractual arrangements, pricing policies and internal compliance procedures. Majstorović & Partners provides comprehensive legal support in the interpretation and application of the regulatory framework, including risk assessment and compliance alignment in the area of trade regulation.

This publication is provided for general information purposes only and does not constitute legal advice or a legal opinion with respect to any specific matter. Legal advice should be obtained based on the particular circumstances of each individual case.