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.
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.
Source: IR (EU) 2026/1740 Annex I, which replaced the Annex I of IR (EU) 2025/2621 from 1 January 2026 · Default = the published total-emissions value · Net cost adds the Annex I mark-up once — 10% in 2026 and 30% from 2028 for cement, iron and steel, aluminium and hydrogen, 1% for fertilisers · Used when verified actual data is not provided
| Product | Sector | Default tCO₂e/t | Net cost 2026 €/t | Net cost 2030 €/t |
|---|---|---|---|---|
Grey Portland cement CN 25232900 | Cement | 1.3800 | €111.42 | €69.55 |
Anhydrous ammonia CN 28141000 | Fertilisers | 2.2500 | €166.80 | €88.10 |
Urea (solid) CN 31021019 | Fertilisers | 1.4500 | €107.49 | €56.78 |
Ammonium nitrate CN 31023090 | Fertilisers | 2.6000 | €192.74 | €101.81 |
Steel semi-finished (BF-BOF) CN 72071114 | Iron & Steel | 2.3975 | €193.57 | €120.83 |
Unwrought aluminium CN 7601 | Aluminium | 0.3600 | €29.07 | €18.14 |
Hydrogen CN 28041000 | Hydrogen | 10.8200 | €873.58 | €545.33 |
Net cost = default tCO₂e/t × €75.28 (Q2 2026, official price of CBAM certificates) × CBAM phase-in factor (2.5% in 2026, 48.5% in 2030). Actual liability depends on verified embedded emissions and SEFA benchmark deduction. Values shown are for illustrative default scenario only.
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 carbon price is paid in Ukraine today, so there is nothing to deduct. The Climate Policy Framework Law of October 2024 mandates an ETS, with a pilot phase from 2026 and full operation expected around 2029. Full certificate costs apply to 2026 and 2027 declarations.
Our reading of Ukraine's own published measures as at September 2026, not an EU-published value — third-country carbon policy changes without warning. Confirm the current position with advisers in the country of production before pricing anything on it.
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.
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Book a demoDefault values sourced from IR (EU) 2026/1740 Annex I (European 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.
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