CBAM Regulatory Update: Methodological Guidelines for Ukrainian Business
In February 2026, Biomass-Carbon LLC publishes its first methodological guidelines on the CBAM regulatory framework for Ukrainian businesses. The document, prepared within the framework of the project “Technical Assistance for the Export of CBAM Goods from Ukraine to the EU” — implemented with the support of the Ministry of Foreign Affairs of the Kingdom of the Netherlands — is designed to assist Ukrainian exporters in adapting to the CBAM definitive period.
As the mechanism has become a full-fledged financial obligation for the payment of embedded emissions since January 1, 2026, these clarifications are becoming critically important for maintaining the competitiveness of Ukrainian goods in the EU market.
These are the first recommendations in a series of three methodological guidelines intended for technical directors, production managers, environmental engineers, and export specialists of Ukrainian enterprises that export or plan to export goods covered by CBAM to the European Union.
Importance for Ukraine
Ukraine confidently holds a key position among the European Union’s strategic trading partners in the sectors covered by CBAM.
According to the European Commission’s official report dated December 16, 2025 (COM(2025) 783), in 2024, Ukrainian exports of relevant products to the EU amounted to approximately 3.3 billion euros (1.8% of GDP). Iron and steel products accounted for almost 90% of this volume, reaching 3.0 billion euros. Cement exports amounted to 139 million euros, while figures for other categories (fertilisers, electricity, and hydrogen) were below 100 million euros.
In the second quarter of 2025, Ukraine’s share of the EU’s total import of CBAM goods was nearly 15%, at 18.4% in the iron and steel segment and 17.4% in cement. At the same time, Ukrainian producers demonstrated one of the highest levels of adaptation to the new rules: the share of imports from Ukraine based on actual data on embedded emissions rose from 15% in the fourth quarter of 2023 to 78% in the second quarter of 2025.
With the start of the CBAM definitive period, EU importers are obliged to purchase specific CBAM certificates to cover the embedded emissions in goods imported into the customs territory of the Union. This creates new challenges for Ukrainian exporters, whose competitiveness in the EU market now directly depends on the efficiency of monitoring and verification of emissions, as well as on the implementation of decarbonisation strategies.
Understanding the CBAM regulatory framework is critical for:
- accurate forecasting of costs for the purchase of certificates;
- avoiding fines and sanctions;
- maintaining competitiveness in the EU market;
- planning investments in measures for the decarbonisation of production.
The methodological guidelines provide a systematised overview of the CBAM regulatory framework, explain key concepts, and contain practical advice for ensuring compliance with the new requirements.
Legislative Architecture and Regulatory Environment of CBAM
The basis of the mechanism is the Basic Regulation (EU) 2023/956. Its main goal is the prevention of “carbon leakage”. This is a situation where, due to strict EU climate requirements, businesses are forced to relocate production to countries with less ambitious environmental standards.
To adapt the mechanism to market realities, the European Parliament and the Council adopted Regulation (EU) 2025/2083. It significantly strengthened CBAM and introduced an important relief – the “de minimis exemption”. Now, importers of small consignments of goods (up to 50 tonnes of total net mass per year) are exempt from obligations, which significantly reduces the administrative pressure on small and medium-sized businesses.
Technical details of the definitive period are regulated by a comprehensive system of implementing acts of the European Commission. These documents establish clear rules regarding:
- the methodology for calculating embedded emissions, taking into account both direct and indirect emissions;
- the operation of the CBAM Registry – a unified electronic database for managing declarations, certificates, and the registration of operators;
- authorisation procedures and the obligations of authorised declarants;
- accreditation of verifiers, principles of verification, and other aspects of the mechanism’s functioning.
Regulatory Framework of the CBAM Definitive Period
| № | Act Title | Content of the Act | Official Link (EUR-Lex) |
| 1 | Regulation (EU) 2023/956 | Establishing the Carbon Border Adjustment Mechanism | https://eur-lex.europa.eu/eli/reg/2023/956/oj/eng |
| 2 | Regulation (EU) 2025/2083 | Simplification and strengthening of the Carbon Border Adjustment Mechanism | https://eur-lex.europa.eu/eli/reg/2025/2083/oj/eng |
| 3 | Implementing Regulation (EU) 2024/3210 | CBAM Registry | http://data.europa.eu/eli/reg_impl/2024/3210/oj |
| 4 | Implementing Regulation (EU) 2025/486 | Authorisation of CBAM declarants | http://data.europa.eu/eli/reg_impl/2025/486/oj |
| 5 | Implementing Regulation (EU) 2025/2210 | Importation of goods into the continental shelf or the exclusive economic zone of EU Member States | https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32025R2210 |
| 6 | Implementing Regulation (EU) 2025/2547 | Methods for calculating embedded emissions | https://eur-lex.europa.eu/eli/reg_impl/2025/2547/oj |
| 7 | Implementing Regulation (EU) 2025/2620 | Adjustment of free allocations | https://eur-lex.europa.eu/eli/reg_impl/2025/2620/oj |
| 8 | Implementing Regulation (EU) 2025/2621 | Default values | https://eur-lex.europa.eu/eli/reg_impl/2025/2621/oj |
| 9 | Delegated Regulation (EU) 2025/2551 | Accreditation of verifiers | https://eur-lex.europa.eu/eli/reg_del/2025/2551/oj |
| 10 | Implementing Regulation (EU) 2025/2546 | Principles of emissions verification | https://eur-lex.europa.eu/eli/reg_impl/2025/2546/oj |
| 11 | Implementing Regulation (EU) 2025/2619 | Communication with customs authorities | https://eur-lex.europa.eu/eli/reg_impl/2025/2619/oj |
| 12 | Implementing Regulation (EU) 2025/2548 | Calculation and publication of the price of certificates | https://eur-lex.europa.eu/eli/reg_impl/2025/2548/oj |
| 13 | Implementing Regulation (EU) 2025/2550 | Changes to the CBAM Registry | https://eur-lex.europa.eu/eli/reg_impl/2025/2550/oj |
| 14 | Implementing Regulation (EU) 2025/2549 | Status of the authorised CBAM declarant | https://eur-lex.europa.eu/eli/reg_impl/2025/2549/oj |
Interaction of CBAM with the EU ETS and Financial Parameters
A key principle of CBAM is its complementarity to the EU Emissions Trading System (EU ETS), established by Directive 2003/87/EC. As the phase-out of free allocation of allowances for the EU industry takes place within the EU ETS, CBAM mirrors this by incrementally increasing financial requirements for importers.
Financial obligations are calculated based on the number of CBAM certificates to be surrendered. Each certificate corresponds to one tonne of CO2e of embedded emissions. The price of a certificate is determined based on the average weighted price of allowances at EU ETS auctions; however, the price publication schedule will change:
- For goods imported in 2026, the certificate price will be calculated as the average quarterly value of EU ETS auction prices;
- Starting from February 1, 2027, when the full sale of certificates commences, their price will be published weekly.
To ensure a non-discriminatory approach, the number of certificates to be surrendered must be subject to adjustment, taking into account the free allowances received by equivalent producers in the EU. Furthermore, authorised CBAM declarants have the right to claim a reduction in the number of certificates based on the carbon price effectively paid in the country of origin (e.g., carbon tax in Ukraine), provided it is supported by documentary evidence and independent verification.
Technical Aspects and Methodology for Monitoring Greenhouse Gas Emissions
For operators of installations in third countries, including Ukraine, it is critically important to understand the system boundaries of production processes to ensure the correct calculation of embedded emissions, followed by their verification. Regulation (EU) 2025/2547 establishes rules that are harmonised to the maximum extent with EU ETS rules to ensure accuracy and prevent the circumvention of obligations.
To calculate embedded emissions, both actual data obtained from monitoring at the installation and default values can be used. However, during the definitive period, verification is mandatory only for actual emission values. Default values are established by the European Commission based on the average emission intensity of the 10 exporting countries with the highest emission intensity for that specific type of good.
A Series of Methodological Guidelines for Ukrainian Business
Given the complexity of the new requirements, Biomass-Carbon LLC, with the support of the Ministry of Foreign Affairs of the Kingdom of the Netherlands within the framework of the development of the foreign policy of the Kingdom of the Netherlands, is commencing the publication of a cycle of specialised editions designed to assist Ukrainian exporters in adapting to the conditions of the CBAM definitive period.
Methodological Guidelines №1, presented herein, cover the general provisions and the regulatory framework of CBAM: from the Basic Regulation to the implementing acts regarding the CBAM Registry, authorisation, etc., and explain the logic of interaction between various EU authorities and economic operators.
Check out the methodological guidelines №1 (in Ukrainian)
Subsequent editions of the series will focus on practical CBAM tools:
- Methodological Guidelines №2 are dedicated to technical guidance on the monitoring and calculation of embedded emissions for operators of installations. They will provide a detailed overview of production routes, system boundaries, and specific requirements for precursors.
- Methodological Guidelines №3 cover the financial and administrative procedures of CBAM. Primary focus will be placed on the specifics of using default values for embedded emissions, approaches for determining free allocations and assessing CBAM financial obligations, the verification process by accredited verifiers, and the procedure for the purchase and surrender of CBAM certificates.
Successful operation in the European market under CBAM conditions requires not only technical preparation but also a deep understanding of regulatory mechanisms. This series of publications will serve as a reliable foundation for ensuring the sustainability of Ukrainian exports and their integration into the European Union’s “green” agenda.
The publication was prepared within the framework of the project “Technical Assistance for CBAM good exports from UA to EU“, which is implemented with the support of the Ministry of Foreign Affairs of the Kingdom of the Netherlands and the Netherlands Enterprise Agency. Funding is provided by the Private Sector Development Program of the Netherlands Enterprise Agency/The Netherlands Enterprise Agency.
The project “Technical Assistance for CBAM good exports from UA to EU” began on November 25, 2024, and will last until February 28, 2026. This project is implemented with the support of the Ministry of Foreign Affairs of the Kingdom of the Netherlands and the Netherlands Enterprise Agency.
