29.09.2026
Ukrainian exporters need practical support to substantiate their emissions data now, while the government needs a coordinated policy to safeguard access to the European market and secure financing for decarbonisation. This was the message from Stanislav Zinchenko, Director of GMK Center, during Energy Club’s online discussion “CBAM, Electricity and the Competitiveness of Ukrainian Industry,” held on 29 September 2026.
In his presentation and subsequent contributions, Zinchenko examined CBAM as a driver of changes in international trade whose implications extend well beyond any single industry. He noted that GMK Center produced its first study on the subject in August 2020. Today, he argued, Ukrainian businesses increasingly need the capacity to manage carbon data and substantiate it for their buyers.
Zinchenko highlighted the growing commercial value of emissions information. European counterparties need data they can use to assess products’ carbon footprints and the associated costs. According to him, difficulties in substantiating these figures are already prompting buyers to turn down Ukrainian goods. He summed up his view of this trend with the phrase “Carbon data — new currency.”
This is why he identified support for exporters on verification and the development of the necessary expertise as urgent priorities. He stressed the need to build capacity among specialists and organisations working on emissions verification and to address accreditation issues more quickly.
“This is about exports. Here and now, not even about the future,” Zinchenko emphasised.
In his assessment, a possible CBAM deferral or special arrangements for Ukraine would not eliminate the need for high-quality data. Work on collecting, substantiating and using that information in trade must therefore continue regardless of the outcome of political negotiations. Zinchenko also expects carbon information to become increasingly important in other export markets.
Discussing the international context, GMK Center’s Director described the spread of carbon regulation as a process capable of reshaping global trade rules. He expects carbon markets, the comparability of emissions prices and consistency between calculation methodologies to play a growing role. He also highlighted discussions about extending CBAM to downstream steel and aluminium products and the importance of electricity-related emissions in products’ carbon footprints.
“I used to say that CBAM would affect everyone,” he noted, explaining why businesses should assess the mechanism’s implications across their production and supply chains.
The speaker identified volatility in European carbon prices as a separate risk for companies. He expressed the expectation that prices would rise over the longer term, while stressing the potential for substantial fluctuations within individual periods. For businesses entering contracts and planning deliveries, he said, this uncertainty increases the need for risk management.
Among the practical responses, Zinchenko highlighted price-risk hedging and digital platforms for managing carbon data. He pointed to solutions that help assess carbon footprints across supply chains, collect information and reduce uncertainty in dealings with counterparties.
Zinchenko linked the longer-term response to CBAM to investment in modernisation. According to the calculations he presented, decarbonising six Ukrainian steel plants would require approximately €15 billion. He estimated that around 85% of this sum would go towards purchasing equipment from European manufacturers. He used this example to illustrate Ukraine’s and the EU’s shared economic interest in such projects.
Investment in decarbonising Ukraine’s energy sector and industry offers “a direct benefit to the European Union,” Zinchenko stressed. He linked that benefit both to orders for technology suppliers and to the achievement of European climate objectives.
At the same time, he challenged the view that increasing carbon costs is, by itself, a sufficient incentive for modernisation. “Taxes never stimulate investment,” he said, explicitly identifying this as his own position. He linked his assessment to limited access to capital, high energy prices and the risk of investment projects being halted.
In the debate about potential Ukrainian carbon payments, Zinchenko emphasised the need to direct revenues towards decarbonisation. In his view, such mechanisms should be assessed according to their ability to support industrial modernisation and preserve production and exports. He warned that additional costs, without the means to invest, could intensify the risk of deindustrialisation.
Another issue he proposed examining was the possible introduction of a Ukrainian carbon border adjustment mechanism. He linked this proposal to the need to consider competitive conditions in the domestic market, where Ukrainian manufacturers face wartime risks while competing with imported products. This was presented as an idea for further discussion.
Zinchenko also devoted considerable attention to the organisation of negotiations with European institutions. He criticised the results of Ukraine’s previous preparations for CBAM and called for more active engagement with political support for Ukraine in the European Parliament. In his view, carbon regulation should be addressed alongside the broader agenda of trade, quotas and access for Ukrainian goods to the EU market.
Asked by moderator Andrii Kulykov to identify a priority action for the next six months, Zinchenko proposed establishing an effective working group on Ukrainian exports to the EU, with involvement at the highest political level.
“We need a real working group with involvement at the highest political level,” he stressed, outlining a remit covering exports, trade policy and CBAM.
In his view, this work should combine the protection of existing export opportunities with practical support for companies on verification and financing for decarbonisation. He framed continued access to the European market as a matter of Ukraine’s day-to-day economic viability during the war.
