12.08.2026
During Energy Club’s expert online discussion “CBAM and Electricity Trade between Ukraine and the EU: Risks, Practical Challenges and the Market Position”, Andrii Makhmurov-Dyshliuk, Head of the Expert Group on Sustainable Development at the Directorate for Strategic Planning and European Integration of the Ministry of Energy of Ukraine, emphasized that CBAM is of particular importance for Ukraine’s electricity sector.
According to him, this issue is directly linked to the further integration of Ukraine’s electricity market into the European Union market.
“For the Ministry of Energy, this issue is of particular importance, as it is directly related to the further integration of Ukraine’s electricity market into the European Union,” Andrii Makhmurov-Dyshliuk said.
The representative of the Ministry of Energy stressed that Ukraine’s electricity sector is potentially one of the most vulnerable to the application of CBAM.
Among the key risks, he mentioned the possibility of a double carbon burden. This refers to a situation in which importers may face both the payment of an environmental tax on emissions in Ukraine and additional obligations at the border under CBAM requirements.
Andrii Makhmurov-Dyshliuk also drew attention to the impact of Russia’s full-scale war against Ukraine. According to him, large-scale destruction of energy infrastructure makes it difficult for Ukraine to move toward new regulatory requirements in a timely and complete manner, as significant state resources are directed toward restoring the energy sector and ensuring national energy security.
“The full-scale war against Ukraine and the catastrophic destruction of energy infrastructure make it impossible for Ukraine to move toward new regulations in a timely and complete manner due to limited resources, which are directed toward energy restoration and the energy security of the state,” he noted.
According to Andrii Makhmurov-Dyshliuk, taking these circumstances into account, in June 2025 the Ministry of Energy addressed the European Commission and the Energy Community Secretariat regarding the exemption of Ukraine’s electricity sector from the application of CBAM for the period of martial law and for five years after its termination or cancellation.
He said that the European Commission did not find grounds to apply a force majeure exemption to Ukraine. At the same time, according to him, the Commission confirmed its readiness to continue dialogue with Ukraine and to review approaches in the event of significant imbalances during the practical implementation of the mechanism.
“The European Commission did not find grounds to apply a force majeure exemption to Ukraine. At the same time, the Commission confirmed its readiness to continue dialogue with Ukraine and to review approaches in the event of significant imbalances during the practical implementation of the mechanism,” Andrii Makhmurov-Dyshliuk said.
The representative of the Ministry of Energy placed particular emphasis on the need for an objective assessment of CBAM’s impact on Ukraine’s electricity sector.
According to him, it is fundamentally important for Ukraine that such an assessment be based on objective data and take into account the real structure of Ukraine’s generation mix, including the significant role of nuclear, hydro and renewable energy.
“For the Ukrainian side, it is fundamentally important that the assessment of CBAM’s impact be based on objective data and take into account the real structure of Ukrainian generation, including the significant role of nuclear, hydro and renewable energy,” Andrii Makhmurov-Dyshliuk emphasized.
He also noted that it is important for the Ministry of Energy to hear expert assessments and the position of business regarding the practical impact of CBAM on Ukraine’s electricity market.
Thus, the key issues for further work remain the recognition of Ukraine’s actual energy mix, prevention of a disproportionate burden on the electricity sector, continuation of dialogue with the European Commission and the Energy Community Secretariat, and the formation of a practical business position on the application of CBAM to electricity trade between Ukraine and the EU.
