09.05.2025
Energy Club has received an official response from the Ministry of Environmental Protection and Natural Resources of Ukraine to the Club’s appeal regarding the potential negative consequences of the European Union’s Carbon Border Adjustment Mechanism (CBAM) for the Ukrainian economy and the energy sector.
It is reminded that on March 28, 2025, Energy Club held an online meeting where key experts and business representatives discussed the challenges and risks associated with the introduction of CBAM. Following the discussions, Energy Club appealed to the Prime Minister of Ukraine to protect the interests of the national energy sector.
In its response, MinDovkillya stated that it had reviewed Energy Club’s letter and provided clarifications on the issues raised.
Key points of MinDovkillya’s response:
Regarding CBAM deferral: MinDovkillya reported that Ukrainian representatives have repeatedly raised the issue of deferring CBAM for Ukraine during meetings with representatives of the European Commission. In particular, this issue was discussed at meetings with representatives of the Directorate-General for Climate Action (DG CLIMА) and the Directorate-General for Taxation and Customs Union (DG TAXUD). DG CLIMA representatives emphasized the importance of coordinating actions with DG TAXUD and expressed their readiness for working contacts to develop specific conditions for the application of CBAM for Ukraine. In addition, the European Commission has proposed postponing the full implementation of CBAM until 01.02.2027.
Regarding legislative adaptation: MinDovkillya is developing a draft Law of Ukraine “On the Principles of the Functioning of the Greenhouse Gas Emission Trading System” to fulfill Ukraine’s international obligations and implement Directive 2003/87/EC of the European Parliament and of the Council. The Cabinet of Ministers of Ukraine has also approved an Action Plan for the creation of a national greenhouse gas emission trading system.
Energy Club continues to closely monitor the development of the situation surrounding CBAM and actively cooperate with the Government of Ukraine and European partners to protect the interests of the domestic energy sector.