Technical Assistance for Exporting CBAM Goods from Ukraine to the EU

Biomass-Carbon, in collaboration with the Green Transition Office, has launched a new project titled "Technical Assistance for Exporting CBAM Goods from Ukraine to the EU." The project is supported by the Ministry of Foreign Affairs of the Kingdom of the Netherlands as part of the Netherlands' foreign policy development. Funding is provided under the Private Sector Development Program of the Netherlands Enterprise Agency.

Background

On October 1, 2023, the European Union introduced the Carbon Border Adjustment Mechanism (CBAM), a new environmental policy tool. CBAM applies to imported products that must account for the same carbon emissions costs as those borne by EU-based facilities.

During the transitional period, from CBAM’s introduction until December 31, 2025, importers are exempt from financial obligations and instead focus on collecting data on CBAM-covered goods. This currently includes products from sectors such as iron and steel, cement, aluminum, fertilizers, hydrogen, and electricity.

Importers in the EU must report the emissions associated with CBAM-covered goods. These include direct and indirect emissions of carbon dioxide, nitrous oxide (for certain fertilizers), and perfluorocarbons (for specific aluminum products). To gather the required information, importers must contact producers for data.

Requirements for Ukrainian Producers

Ukrainian producers exporting or planning to export CBAM goods to the EU must be prepared to provide accurate emissions data. From Q3 2024, the use of default values for emissions will be restricted, making precise calculations mandatory.

To meet these requirements, Ukrainian producers need to:

• Develop monitoring methodology documentation for their facilities according to CBAM standards.
• Implement monitoring systems to collect data and calculate specific embedded emissions of their products.

The methodology for emissions calculation is regulated by Implementing Regulation (EU) 2023/1773.

Future Changes to CBAM

By the end of the transitional period, the European Commission will review CBAM’s implementation and may expand the list of covered goods. Starting January 1, 2026, the main phase will begin, requiring EU importers to purchase CBAM certificates to account for the embedded emissions in imported goods.

Over the following 10 years, the allocation of free CBAM certificates will gradually decrease, ending entirely by 2035.

About the Technical Assistance Project

The project aims to strengthen the export capacity of Ukrainian producers in sectors currently exporting or planning to export goods to the EU under CBAM.

Key initiatives include:

• Selecting three Ukrainian CBAM producers from two different sectors (iron and steel, cement, fertilizers, aluminum).
• Providing advisory support on monitoring, emissions calculation, data transfer to importers, and further export to the EU.

Additionally, three methodological documents will be developed for stakeholders:

1. General recommendations for calculating embedded emissions.
2. Two specialized methodologies for individual industrial sectors.

Additional Measures

The project will include regular updates published on the Biomass-Carbon and Bioenergy Association of Ukrainewebsites and a series of webinars.

Expected Outcomes

Expert support for Ukrainian producers will enhance their export potential, contribute to economic growth, and improve Ukraine’s competitiveness amid climate challenges and the transition to decarbonization.

Project Details

The project began on November 25, 2024, and will run until February 28, 2026. It is supported by the Ministry of Foreign Affairs of the Kingdom of the Netherlands and the Netherlands Enterprise Agency.

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