According to the Ukrainian Union of Industrialists and Entrepreneurs (USPP), several major associations, including "Ukrmetalurgprom," the Union of Chemists of Ukraine, the "Ukrcement" association, and the All-Ukrainian Union of Construction Materials Manufacturers, are addressing the President of the European Commission. They are calling for a special approach to Ukraine regarding the Carbon Border Adjustment Mechanism (CBAM). As of January 1, 2026, the EU plans to transition to the full financial regime of this mechanism, covering steel, cement, fertilizers, aluminum, and electricity. These are sensitive export positions for Ukraine, and business groups emphasize the need to account for wartime circumstances during the implementation of European climate regulations.
Business Perspective: Key Risks for Ukrainian Exports
The appeal notes that Ukrainian enterprises are adapting to environmental requirements amidst full-scale war, the destruction of energy and industrial infrastructure, electricity shortages, logistical constraints, and personnel deficits. Data shows that in January-February of this year, Ukraine's GDP already contracted by 1.2%, while defense spending accounts for 31% of the budget. Under such pressure, the rapid full-scale implementation of CBAM could deliver an additional blow to export-oriented sectors.
Industrial associations also highlight the risk of using "default" CO2 emission factors. According to businesses, the parameters proposed by the European Commission exceed the actual emissions of many Ukrainian producers, leading to inflated future payments. Environmental verification remains another challenge, as a significant number of enterprises operate in frontline regions under constant shelling.
Impact on the Metal Market and Solutions from winox.ua
For the steel and metal markets, the consequences could be systemic, as CBAM without a transition period may reduce the competitiveness of Ukrainian products in the EU. The report mentions estimates from GMK Center, stating that since the mechanism's introduction, Ukrainian steelmakers have already lost over 1.1 million tons in export orders to the European Union. This creates risks of reduced production, lower employment, and stalled modernization investments.
Under such conditions, stability of supply and predictability of procurement become particularly important for metal consumers in Ukraine. This is why winox.ua, as a supplier of rolled metal, stainless steel, and non-ferrous metals, focuses on providing reliable support to industrial clients and helping mitigate operational risks during periods of market turbulence. For B2B customers, this means access to systematic supplies and more controlled procurement planning amid regulatory changes in the EU.
Proposed Solutions for the European Commission
Business associations propose applying a special procedure to Ukraine in accordance with Article 30.7 of EU Regulation 2023/956, providing for a transition period. Such an approach, they believe, should account for the extraordinary conditions of the war and give manufacturers time to correctly adapt to new decarbonization rules. This is not about rejecting the EU's climate goals but about finding a realistic model for integrating Ukrainian industry into the European regulatory space.
For the metallurgy, cement, fertilizer, and aluminum industries, the decision regarding Ukraine's CBAM status will directly impact export revenue and the pace of post-war recovery. If the EU considers these business arguments, it will reduce the risk of unjustified financial burdens and preserve the country's industrial potential. Otherwise, the market could face a further decline in exports and new layoffs in the manufacturing sector.