Ukrainian cement producers require equal conditions with their European counterparts in the implementation of the Carbon Border Adjustment Mechanism (CBAM) from 2026.

“While EU companies have support and equal conditions for investments in decarbonization, Ukrainian companies do not have such support. During martial law, the cost of CBAM certificates puts Ukrainian exports at a disadvantage compared to EU producers and creates additional obstacles for Ukrainian enterprises, exacerbating the negative consequences of the war,” said Lyudmila Krypka, executive director of the Ukrcement Association, on Wednesday during the event “CBAM and the readiness of Ukrainian industry for decarbonization: from methodology to competitive advantage,” organized as part of the STEP IN 2 EU program.

She reminded that Ukraine does not have developed financial markets that would allow it to attract funding for decarbonization. Instead, there are challenges and barriers, one of which is the war and constant round-the-clock rocket and drone attacks, destroyed energy facilities, including generation, staffing problems due to mobilization and emigration, and much more.

As reported, on December 17, 2025, the European Commission (EC) took measures to strengthen the effectiveness of the Carbon Border Adjustment Mechanism (CBAM). From 2026, updated, stricter benchmarks will come into force and a surcharge will be applied to the default values: 10% (2026), 20% (2027), and 30% (from 2028).

According to the expert, to ensure transparency and meaningful participation of all relevant stakeholders, it is important to review the default values as early as 2026, as the values proposed for Ukraine range from 1,500 to 1,794, which are several times higher than the actual figures.

Thus, actual CO2 emissions in the 1990s amounted to 0.956 kg, provided that a larger number of enterprises in the industry (up to 15 enterprises) were operating and production amounted to 17-18 million tons; from 2017 to 2020, emissions decreased from 891 to 879 kg (production decreased from 6,333 to 7,419 thousand tons, the number of enterprises was 10). According to forecasts, in 2025, emissions will be around 0.700 kg, not 1,500.

“The production of 1 ton of cement clinker emits approximately 850 kg of CO2. When using alternative fuels, 90% of CO2 emissions will amount to 672 kg/1 ton of clinker,” Krypka gave an example.

Unfortunately, she added, the alternative fuel market in Ukraine is not working, and Ukrainian cement producers buy it in the EU. Over the past two years, cement companies have been using 20 to 30% alternative fuels, with the goal of increasing the share of alternative fuels to 40% by 2030.

Ukrcement has made a number of proposals to level the playing field for Ukrainian companies subject to the ETS. First of all, our producers should receive free quotas similar to those in the EU; the tax should be applied to actual emissions, not default values; Ukrainian legislation needs to be harmonized with EU rules on biomass taxation. It is also necessary for producers to be able to use tax “environmental” payments to decarbonize their own enterprises. Cooperation with European verifiers and training courses on CBAM calculation are important.

The Ukrcement Association was established in January 2004 through the reorganisation of the Ukrainian Concern of Cement Industry Enterprises and Organisations “Ukrcement”. The association has four members, comprising eight enterprises that meet 100% of the domestic Ukrainian market’s cement needs.

SBA Ukrcement

Last modified: January 21, 2026