CBAM and Electricity Trade between Ukraine and the EU: Risks, Market Impact and Practical Solutions

Energy Club will hold an expert online meeting dedicated to the impact of the CBAM mechanism on electricity trade between Ukraine and the European Union.

The introduction of a full-fledged CBAM mechanism creates new economic and regulatory challenges for Ukrainian traders, electricity producers and European importers. For the electricity market, this issue is already of practical importance, as it may affect the competitiveness of Ukrainian electricity in the EU, the export price, trade margin, contract terms, the distribution of financial obligations between the seller and the importer, as well as the prospects for Ukraine’s further integration into the European electricity market.

Of particular importance is the issue of taking into account the actual carbon intensity of Ukrainian electricity. In the absence of a coordinated approach, Ukrainian companies may face the risk that the CBAM component will be included in the import price by default, even in cases of electricity exports from nuclear, hydro or renewable generation.

Based on the results of the discussion, the Energy Club plans to form a further work plan, prepare practical materials for market participants, hold consultations with Ukrainian authorities and present a consolidated position of the Ukrainian energy business at the international level.

Questions for discussion

1. How can CBAM affect Ukrainian electricity exports to the EU?
   Impact on price, margin, contracts, use of cross-border capacity and competitiveness of Ukrainian companies.
2. Can Ukrainian electricity confirm actual carbon intensity?
   Practical possibilities, limitations, required data, documents and the role of electricity origin.
3. How does CBAM affect electricity from nuclear, hydro and renewable generation?
   Is there a risk of applying an excessive CBAM component to low-carbon Ukrainian electricity?
4. What practical issues arise for traders, manufacturers and European importers?
   Distribution of responsibility, CBAM declarant, contractual terms, reporting, financial obligations and risks for trade operations.
5. What position does the Ukrainian energy business need?
   What should be the subject of joint advocacy before the Ukrainian authorities, the Energy Community and EU institutions.

Energy Club invites member companies of the Club and interested market participants to join the discussion, share practical experience and proposals for forming a joint position of the Ukrainian energy business.

Moderator

Artem Martyniuk

vice president of Energy Club, Acting Director General of Ukrainian Distribution Networks JSC (August 2023 - September 2025)