← All Countries

Ukraine — CBAM Guide

Iron & Steel is Ukraine's dominant CBAM-covered export — with significant EU market volumes and an EU accession candidacy that may affect future CBAM treatment.

Iron & SteelCement
First declaration deadline
30 Sep 2027
De minimis threshold
50 t / year
Carbon pricing
None — ETS in development
EUA price Q1 2026
€75.36 / tCO₂e
CBAM phase-in 2026
2.5% of full liability
CBAM phase-in 2030
48.5% of full liability

Trade Profile

Ukraine is a major EU supplier of pig iron, flat-rolled steel, and semi-finished steel products. Metinvest and ArcelorMittal Kryvyi Rih are among the largest Ukrainian steel exporters. Ukraine holds EU accession candidate status — future integration with the EU ETS may eventually exempt Ukrainian goods from CBAM, though this remains a long-term scenario.

Article 9 — Carbon Price Deduction

No deduction

Carbon pricing in Ukraine: Ukraine does not operate a domestic carbon pricing mechanism applicable to CBAM-covered goods. An ETS is in development as part of EU accession alignment.

No qualifying carbon price currently applies to Ukrainian production. Ukraine's EU accession candidacy and ETS development may eventually create an exemption from CBAM, but this requires full EU membership and ETS linkage. For 2026 and 2027 declarations, the full CBAM certificate cost applies.

Compliance Insight for Ukraine Exporters

Ukrainian steel (2.40 tCO₂e/t semi-finished, BF-BOF) is above the SEFA benchmark. Ukraine's EU Association Agreement means significant steel volumes are already flowing to the EU — CBAM compliance is a priority for 2027. Producers should engage accredited verifiers now given the lead time required.

Verify Your Actual Emissions →

Four Steps to Compliance

1
Register in the CBAM Operators Portal
Upload installation identification data: legal name, UN/LOCODE, GPS coordinates, contact person. This enables your EU buyer's authorised declarant to access your verified data.
2
Establish a monitoring plan
Document all energy inputs, production outputs, and emission calculation methodology per the governing EU implementing regulation. This is the foundation for any verified data submission.
3
Engage an accredited verifier
Appoint a third-party verifier accredited under EN ISO/IEC 14065 by an EA-recognised National Accreditation Body. A physical site visit is required before verified data can be submitted.
4
Share verified data with your EU buyer
Provide verified specific embedded emissions to your EU buyer's authorised CBAM declarant before the September 2027 declaration deadline. Verified actual data replaces default values — typically at significantly lower cost.

Key Deadlines

2026
First full reporting year begins
CBAM Regulation fully in force
30 Sep 2027
First CBAM declaration due
Covers goods imported in 2026
2028+
Annual declarations continue
Phase-in increases each year to 2034
2034
Full CBAM liability
100% of certificates required

Calculate your exposure

Estimate your 2026–2034 CBAM certificate costs using your sector, volume, and production route.

Free Sector Calculator →

Country Assessment Report

Need a verified, installation-specific CBAM exposure report for Ukraine? Our Country Assessment covers default vs actual emission gaps, benchmark comparison, and a 2026–2034 cost trajectory.

Request Assessment →

Default values sourced from IR 2025/2621 (EU Commission). Net costs are illustrative — actual liability depends on verified embedded emissions, SEFA benchmark deduction, and the applicable CBAM phase-in factor. Not legal or compliance advice.