CBAM: Challenges for Ukrainian Exports and the Role of ESS

22/ 10/ 2025

Listen to online Stop   In 2022, after the start of the full-scale invasion, the EU temporarily lifted tariffs and quotas on Ukrainian exports to support its economy. However, in June 2025, this preferential regime expired. A number of EU member states, which perceive Ukrainian agricultural exports as competition for their own producers, initiated the reinstatement of trade restrictions. The first sector to feel the impact was agri-food, which last year accounted for nearly 60% of all Ukrainian exports. At the same time, another challenge emerges for Ukraine’s economy — CBAM, which may hit not only agriculture but also industry and energy companies. CBAM (Carbon Border Adjustment Mechanism) is an EU instrument designed to combat “carbon leakage”: imports into the European Union will be subject to tariffs if their production involves significant greenhouse gas emissions. Clean Energy, but Taxed: What CBAM Means for Ukraine. CBAM will come into force on January 1, 2026, and poses serious risks for Ukraine’s key export industries: metallurgy, cement production, fertilizers, and also electricity exports generated from coal or gas. Ukraine is among the countries with one of the cleanest electricity generation structures in Europe: more than 50% of electricity is produced by nuclear power plants, which the EU officially recognizes as carbon-neutral; 11% came from renewables in 2024 — mainly solar and wind; about 10% — from large hydropower plants. The remaining share of Ukraine’s electricity exports comes from thermal power plants running on coal or gas — and this portion will be subject to the carbon tax. But even “clean” solar generation has its problem: during daytime peak hours, both in Ukraine and the EU, there is often an oversupply. Consequently, exports at this time lose economic viability. The situation is further complicated by seasonality: in spring, when nuclear units have not yet gone into maintenance, and in autumn, when demand is still relatively low, Ukraine can sell surplus electricity abroad. In summer, however, despite high solar generation, the EU market often experiences oversupply as well, which limits the profitability of Ukrainian supplies. As a result, although Ukraine’s share of “clean” energy is high, its export faces market barriers. These restrictions, combined with the introduction of CBAM, could reduce the economic value of Ukrainian renewable energy for the European market. ESS — Part of the Solution. Energy Storage Systems (ESS) are becoming a critically important tool for modern energy. They allow excess electricity to be stored during the day and released during peak demand hours — when it is truly needed and has the highest value. A trend toward the implementation of ESS is already forming among Ukrainian electricity producers. This is logical: more than three-quarters of Ukrainian electricity has a low carbon footprint (nuclear and renewables). Under the right conditions and with infrastructure development, Ukraine could become a competitive supplier of “clean” energy to Europe. Moreover, the role of ESS grows sharply in the context of European integration processes related to CBAM. Another key aspect is the upcoming market coupling (full integration of the Ukrainian and European electricity markets, planned for 2027). In this process, ESS will play a dual role: technical — ensuring balance between production and consumption; economic — allowing operators to optimize price differences between markets and increase profitability. Thus, the development of ESS is not only a tool for energy system stability, but also a strategic prerequisite for Ukraine’s successful European integration and entry into the EU market as a supplier of “clean” energy. Will there be a Deferral for Ukraine?. Industry associations, including Energy Club and Ukrcement, have already appealed to the government to initiate negotiations with the European Commission on the possibility of deferring CBAM implementation for Ukraine. As of May 2025, there was information about a possible postponement of CBAM for Ukraine until 2027 — the same year when market coupling is planned. This would allow the use of PPA (Power Purchase Agreements), enabling producers to avoid the carbon tax. However, as of now, the EU still does not recognize Ukrainian PPA agreements, creating obstacles for the “green” export of electricity. In the renewable energy market, there are two main types of agreements that allow companies to purchase electricity with a confirmed low carbon footprint: Physical PPAs — direct contracts between producer and buyer providing for electricity supply at a fixed price. Virtual PPAs — financial agreements where no physical supply occurs, but a contract for difference (CfD) is concluded, fixing the agreed price. This allows companies to hedge risks and confirm the “green” origin of electricity, even if it is not delivered physically. Macroeconomic Consequences. The introduction of CBAM may have a significant impact on Ukraine’s macroeconomic stability. Exports traditionally account for a large share of GDP, so new barriers such as the carbon tax may lead to reduced foreign revenues, fewer jobs, and slower economic growth. In these conditions, the key factor will be the state’s ability to adapt: through the green transition, integration into the EU energy market, and the development of low-carbon technologies. CBAM is a serious challenge for Ukrainian exporters but also an opportunity to accelerate the green transition. Integration into the EU energy market, the development of low-carbon technologies, and recognition of Ukrainian PPAs can preserve the competitiveness of our products and ensure stable access to European markets.

In 2022, after the start of the full-scale invasion, the EU temporarily lifted tariffs and quotas on Ukrainian exports to support its economy. However, in June 2025, this preferential regime expired. A number of EU member states, which perceive Ukrainian agricultural exports as competition for their own producers, initiated the reinstatement of trade restrictions. The first sector to feel the impact was agri-food, which last year accounted for nearly 60% of all Ukrainian exports.

At the same time, another challenge emerges for Ukraine’s economy — CBAM, which may hit not only agriculture but also industry and energy companies. CBAM (Carbon Border Adjustment Mechanism) is an EU instrument designed to combat “carbon leakage”: imports into the European Union will be subject to tariffs if their production involves significant greenhouse gas emissions.

CBAM will come into force on January 1, 2026, and poses serious risks for Ukraine’s key export industries: metallurgy, cement production, fertilizers, and also electricity exports generated from coal or gas.

Ukraine is among the countries with one of the cleanest electricity generation structures in Europe:

• more than 50% of electricity is produced by nuclear power plants, which the EU officially recognizes as carbon-neutral;
• 11% came from renewables in 2024 — mainly solar and wind;
• about 10% — from large hydropower plants.

The remaining share of Ukraine’s electricity exports comes from thermal power plants running on coal or gas — and this portion will be subject to the carbon tax.

But even “clean” solar generation has its problem: during daytime peak hours, both in Ukraine and the EU, there is often an oversupply. Consequently, exports at this time lose economic viability. The situation is further complicated by seasonality: in spring, when nuclear units have not yet gone into maintenance, and in autumn, when demand is still relatively low, Ukraine can sell surplus electricity abroad. In summer, however, despite high solar generation, the EU market often experiences oversupply as well, which limits the profitability of Ukrainian supplies.

As a result, although Ukraine’s share of “clean” energy is high, its export faces market barriers. These restrictions, combined with the introduction of CBAM, could reduce the economic value of Ukrainian renewable energy for the European market.

ESS — Part of the Solution

Energy Storage Systems (ESS) are becoming a critically important tool for modern energy. They allow excess electricity to be stored during the day and released during peak demand hours — when it is truly needed and has the highest value.

A trend toward the implementation of ESS is already forming among Ukrainian electricity producers. This is logical: more than three-quarters of Ukrainian electricity has a low carbon footprint (nuclear and renewables). Under the right conditions and with infrastructure development, Ukraine could become a competitive supplier of “clean” energy to Europe.

Moreover, the role of ESS grows sharply in the context of European integration processes related to CBAM. Another key aspect is the upcoming market coupling (full integration of the Ukrainian and European electricity markets, planned for 2027). In this process, ESS will play a dual role:

• technical — ensuring balance between production and consumption;
• economic — allowing operators to optimize price differences between markets and increase profitability.

Thus, the development of ESS is not only a tool for energy system stability, but also a strategic prerequisite for Ukraine’s successful European integration and entry into the EU market as a supplier of “clean” energy.

Will there be a Deferral for Ukraine?

Industry associations, including Energy Club and Ukrcement, have already appealed to the government to initiate negotiations with the European Commission on the possibility of deferring CBAM implementation for Ukraine.

As of May 2025, there was information about a possible postponement of CBAM for Ukraine until 2027 — the same year when market coupling is planned. This would allow the use of PPA (Power Purchase Agreements), enabling producers to avoid the carbon tax.

However, as of now, the EU still does not recognize Ukrainian PPA agreements, creating obstacles for the “green” export of electricity.

In the renewable energy market, there are two main types of agreements that allow companies to purchase electricity with a confirmed low carbon footprint:

• Physical PPAs — direct contracts between producer and buyer providing for electricity supply at a fixed price.
• Virtual PPAs — financial agreements where no physical supply occurs, but a contract for difference (CfD) is concluded, fixing the agreed price. This allows companies to hedge risks and confirm the “green” origin of electricity, even if it is not delivered physically.

Macroeconomic Consequences

The introduction of CBAM may have a significant impact on Ukraine’s macroeconomic stability. Exports traditionally account for a large share of GDP, so new barriers such as the carbon tax may lead to reduced foreign revenues, fewer jobs, and slower economic growth.

In these conditions, the key factor will be the state’s ability to adapt: through the green transition, integration into the EU energy market, and the development of low-carbon technologies.

CBAM is a serious challenge for Ukrainian exporters but also an opportunity to accelerate the green transition. Integration into the EU energy market, the development of low-carbon technologies, and recognition of Ukrainian PPAs can preserve the competitiveness of our products and ensure stable access to European markets.