Energy Club initiates active steps to postpone CBAM: new responses from the Ministry of Energy

13.05.2025

Energy Club, as the leading association of energy companies in Ukraine, continues to actively defend the interests of the domestic energy sector in connection with the introduction of the Carbon Border Adjustment Mechanism (CBAM) by the European Union. The Club has received new responses from the Ministry of Energy of Ukraine (Minenergo) regarding the measures taken.

Position and actions of Minenergo

Minenergo expresses deep concern about the potential negative impact of CBAM on the Ukrainian economy and the energy sector, especially in the context of the ongoing military aggression of the Russian Federation.

In its letters, particularly in response to numerous appeals from energy companies (Minenergo’s letter of 08.05.2025), Minenergo clearly articulates its position. In addition, Energy Club has at its disposal an internal letter from Minenergo dated 07.05.2024, addressed to the Ministry of Environmental Protection and Natural Resources of Ukraine (MinDovkillya) and the Ministry of Economy of Ukraine, which also outlines the key points:

• CBAM should not apply to Ukrainian goods and services, especially electricity, since Ukraine is already implementing a carbon emission trading system similar to the EU.
• The most appropriate approach is to apply a declarative approach to Ukraine without levying charges for greenhouse gas emissions, in accordance with the provisions of Article 30 (7) of the EU Regulation.
• Minenergo has initiated the preparation of an official appeal to the European Commission and the Energy Community Secretariat with a request for a temporary exemption of Ukraine’s energy complex from CBAM for the duration of martial law.

Position of the Ministry of Environmental Protection

Previously, Energy Club already informed about the received response from MinDovkillya, which stated:

• Ukraine is actively negotiating with the European Commission on the possibility of postponing CBAM.
• The European Commission has proposed postponing the full implementation of CBAM until 01.02.2027.
• MinDovkillya is working on adapting national legislation to EU requirements, particularly in the field of emission trading.

Conclusion

The responses received from Minenergo, as well as the position of MinDovkillya, emphasize the importance of coordinated actions of the Government and the energy community to protect the interests of Ukrainian energy. Energy Club continues to closely monitor the development of the situation and inform about all the key stages.