Calculation of greenhouse gas (CO 2 ) emissions for Ukrainian exporters using the CBAM mechanism

From October 1, 2023, importers to the European Union will report CO 2 emissions. The European
Union developed the world's first carbon border adjustment mechanism (Carbon Border Adjustment
Mechanism, CBAM) and on April 18, 2023, the European Parliament approved it. It should be noted
that since 2005, a mechanism for regulating carbon emissions has been operating in the EU – the
emissions trading system (EU Emissions Trading System, EU ETS).

What is CBAM for?

The CBAM system aims to prevent "carbon leakage" by subjecting certain groups to imports
products from third countries (not members of the EU and EFTA) of carbon emissions associated
with
the carbon price paid under the EU Emissions Trading System
(ETS) when the same goods are produced in the EU.

Who will be affected by the implementation of CBAM in Ukraine?

CBAM will cover the following product categories (listed in Annex1 REGULATION (EU)
2023/956):
– Kaolin and other kaolin clays, burned
– Cement, alumina cement, cement clinkers, etc.
– Fertilizers (e.g. ammonia, nitric acid, sulphonitric acid)
– Metallurgy, full coverage of iron and steel products (except some ferroalloys, scrap, etc.)
– Iron and steel products include the following products such as screws, bolts, nuts, screws,
screw hooks, rivets, cotter pins, washers (including spring washers) and similar products
– Aluminum structures and parts of structures
– Some aluminum tanks, tanks, containers
– Stranded wire, cables, braided tapes, etc., of aluminum, no electrical insulation
– Other aluminum products
– Agglomerated Iron Ores and Concentrates
– Hydrogen

What would the implementation of the CBAM Regulation look like?

The producer of goods subject to the carbon border adjustment of CBAM, upon its import into the
EU, must pay for the CO 2 emissions released as a result of its production by purchasing CBAM
certificates at a price that will be formed by the EU ETS greenhouse gas emission quota trading
market.

From October 1, 2023 to December 31, 2025, there will be a transition period during which the
importer only reports CO 2 emissions and does not pay for them.
– total quantity of each type of goods expressed in MWh for electricity and in tons for other
commodities, per installation producing the commodity in the country of origin
– actual total emissions expressed in tons of CO 2 emissions per MWh for electricity or for other
goods in tons of CO 2 emissions per ton of each type of goods
– total indirect emissions
– carbon price payable in the country of origin for emissions in imported goods, subject to
appropriate rebates or any other forms of compensation.
From December 31, 2024, the manufacturer will be able to apply for registration in the CBAM
electronic register and register an authorized CBAM applicant (importer), who will be provided
with information on verified CO 2 emissions from the production of goods. The authorized CBAM
applicant must be approved (authorized) by the competent authority in the country to which the
import is carried out.

Preparation for CBAM and basic steps

The main steps that business can take to prepare for the CBAM transition period are:
Step 1
An initial assessment of greenhouse gases is needed. Determine which of your products will be
covered? Where do you get them from (origin)? What is the volume of your imports of these
products? The CBAM transition period is scheduled to begin on October 1, 2023. This requires EU
importers to start reporting the emissions embedded in the CBAM products they import.
Step 2
A process for collecting embedded emissions data should be developed: who in the supply chain has
this information? Who will contact the suppliers?
Step 3
Configure CBAM reporting processes: add to Your Organization’s Business Processes, appoint a
responsible person for compliance with CBAM requirements.
Please note that failure to comply with the requirements of the Regulation entails the imposition of a
fine followed by a ban on trade in the EU.

How can we help you?

If you have any questions about CBAM and its impact on your business, don't hesitate to contact us.
Center LTD specialists help you with the CBAM impact assessment, the preparation of a quarterly
report and the determination of the price to be paid in the country of origin for the embedded
emissions in imported goods, taking into account the relevant discounts or any other forms of
compensation.

Contacts for providing an individual offer: 41 Sakharova St., Lviv, 79026
380 96 781 05 37, [email protected]