29.09.2026
On 29 September 2026, Energy Club held an online Energy Freedom discussion entitled “CBAM, Electricity and the Competitiveness of Ukrainian Industry.” Participants examined how the EU’s Carbon Border Adjustment Mechanism affects Ukrainian exporters, the opportunities offered by low-carbon generation, and the steps needed to substantiate emissions data and maintain access to the European market. The discussion was moderated by journalist and broadcaster Andrii Kulykov.
The event continued Energy Club’s dedicated project on CBAM and its implications for energy, industry and trade with the European Union. Following an initial meeting focused on electricity trade, the Club broadened the discussion to cover industrial exports, financing for decarbonisation and the use of data on the carbon intensity of production.
Stanislav Zinchenko, Director of GMK Center, presented CBAM as a driver of long-term changes in international trade. He highlighted discussions about extending the mechanism’s scope, the risks associated with fluctuations in European carbon prices, and the growing importance of reliable emissions data in relationships between suppliers and buyers. In his assessment, difficulties in substantiating such data are already affecting European counterparties’ willingness to purchase Ukrainian products.
Zinchenko placed particular emphasis on access to financing for modernisation. He argued that even potential special arrangements for Ukraine under CBAM would not remove the need to invest in industrial and energy-sector decarbonisation. In his view, higher carbon payments alone cannot secure these investments, particularly amid war, limited access to capital and high production costs.
Serhii Shemlii, a manager in the Regulatory Affairs Department at JSC Market Operator, examined the economic implications of different approaches to carbon pricing in Ukraine. He presented for discussion a differentiated payment model covering emissions associated with the production of goods exported to the EU and subject to CBAM. His proposal envisages retaining the associated revenues in Ukraine, provided those payments can be appropriately taken into account under CBAM.
The proposal prompted a debate about the distribution of financial costs between producers and buyers, the impact on competitiveness, and the subsequent use of revenues. Zinchenko stressed the need to direct resources towards decarbonisation and take account of industrial companies’ actual circumstances. The exchange revealed differing views on policy instruments and the need for further work on the proposed models.
Oleksii Orzhel, Head of the Kyiv Office of the Energy Community Secretariat, focused on the relationship between CBAM, cross-border trade and energy market integration. He highlighted additional barriers to electricity exports and identified robust emissions verification as a key area for practical action in Ukraine.
Orzhel emphasised the importance of establishing the conditions needed to substantiate actual emissions values, allowing their use instead of default values where CBAM rules permit. He identified cooperation between Ukrainian specialists and European accredited verifiers as one possible route. He also cautioned against treating electricity guarantees of origin as equivalent to emissions evidence for CBAM purposes: the instruments serve different objectives, and a guarantee of origin does not, by itself, resolve verification requirements.
Addressing the possibility of special arrangements for Ukraine in light of the war, the Secretariat’s representative also pointed to the complexity and duration of the relevant EU regulatory procedures. In this context, he stressed the importance of practical work on emissions data and verification systems.
Oleksandr Nemtsov, Head of the Ecology Department within the Nuclear and Radiation Safety Directorate at JSC NNEGC Energoatom, highlighted the potential of nuclear generation as a source of electricity with low direct greenhouse gas emissions. He emphasised the need to move beyond general statements about Ukraine’s substantial share of low-carbon generation and towards substantiating the characteristics of electricity used by individual enterprises and how those characteristics are reflected in their products’ carbon footprints. He noted that the company publishes information on its emissions and undergoes annual verification under Ukraine’s monitoring, reporting and verification system.
In the closing discussion, Zinchenko proposed establishing a working group on Ukrainian exports to the EU with involvement at the highest political level, and identified support for verification as an urgent task. Orzhel called for coordinated work to substantiate emissions from Ukrainian generation and enable exports of low-carbon electricity. Shemlii highlighted the importance of up-to-date data for calculations and the need to align CBAM rules with the process of market coupling.
The meeting also highlighted the distinction between electricity exported as a commodity and electricity consumed in industrial production. As Shemlii explained, these cases need to be considered separately when assessing emissions and applying CBAM.
Energy Club is continuing its dedicated CBAM project by gathering practical business questions and proposals, preparing interviews with Ukrainian and international experts, and developing joint documents. Closing the meeting, Kulykov invited companies to submit specific questions, examples and calculations to help shape a shared business position.
