Ukraine has not yet approached the EU regarding a CBAM deferral – NAEIU

The National Association of Extractive Industries of Ukraine (NAEIU) has warned of growing risks to domestic industry due to the Ukrainian government’s failure to submit an official request for a postponement of CBAM, the European Union’s cross-border carbon adjustment mechanism. This is stated in a report by the association.

According to an analytical report by S&P Global dated July 27, 2025, Ukraine had a real opportunity to obtain a temporary exemption from CBAM, citing force majeure circumstances caused by full-scale war. To do this, it was necessary to initiate an amendment to Article 30.7 of the EU Regulation and submit a corresponding request to the European Commission.

However, the report states that as of the end of July, no request had been submitted by the Ukrainian government.

The NAEIU warns that if the Ukrainian side does not take advantage of this opportunity in the near future, the consequences for the economy will be critical. Already in the first years of CBAM, up to 20% of Ukrainian exports to the EU — in particular steel, cast iron, cement, and fertilizers — will be at risk. As a result, foreign exchange earnings could decrease by $1.44 billion, and GDP losses could reach 4.8-6.3%.

“The issue of CBAM is critical for Ukraine’s export-dependent industry,” NAEIU emphasizes.

The association calls on the Cabinet of Ministers to immediately initiate a dialogue with the European Commission on postponing or softening the conditions for Ukrainian producers.

In particular, the NAEIU appeals to Deputy Prime Minister for European Integration Taras Kachka with a request to take the situation under personal control.

“Procrastination is a direct path to the loss of jobs, export contracts, and Ukraine’s strategic presence in the EU market,” the appeal emphasizes.

It should be recalled that leading Ukrainian industry associations are appealing en masse to the government and the prime minister with a demand to urgently submit an official request to the EC to postpone the implementation of CBAM. Otherwise, Ukraine may lose a significant part of its exports to the European Union as early as 2026. In particular, over the past four years, the European Business Association has been addressing the government on this issue several times a year, participating in all discussions and constantly providing its calculations to all ministries.

According to GMK Center’s revised estimates, Ukraine exported $24.8 billion worth of goods to the EU in 2024, of which 14.5% is subject to CBAM. This primarily concerns iron, steel, electricity, aluminum, cement, and fertilizers. Analysts predict that, given the current structure, the potential losses of Ukrainian exports for 2026-2030 due to the introduction of the mechanism will amount to $4.7 billion, with investment losses for the same period amounting to $2.7 billion.