Nuclear generation supplies at least 60% of Ukraine’s electricity, according to Energoatom’s Ecology Department head Oleksandr Nemtsov, who said low direct greenhouse gas emissions could provide an advantage for industrial exporters supplying European markets.
Speaking at an Energy Club discussion on 29 September, Nemtsov said the benefit depends on establishing evidence connecting low-carbon electricity generation with the electricity consumed by individual industrial users.
Generation data does not establish factory-level consumption
Energoatom publishes monthly emissions information and calculations per kilowatt-hour and undergoes annual verification under Ukraine’s monitoring system, Nemtsov said.
Those records provide information about the characteristics and emissions of electricity generation. They do not, however, demonstrate by themselves how much qualifying electricity a particular industrial facility consumed.
The distinction is relevant because Ukraine’s interconnected electricity system combines generation from different technologies. A national share of nuclear generation and the emissions factor attributable to an individual factory’s electricity consumption address different aspects of the calculation.
Using the national generation mix as a direct substitute for factory-level evidence could therefore overstate the support available for a product-level emissions claim.
EU methodology distinguishes electricity factors and supply evidence
The European Commission’s work on indirect emissions similarly distinguishes country-level electricity factors from the conditions governing the use of actual electricity supply information.
Its technical study examines power-purchase agreements and direct electricity connections, together with safeguards intended to prevent existing clean electricity generation from being assigned to exports without corresponding emissions reductions elsewhere.
For Ukrainian industrial producers, the relevant evidence therefore needs to connect electricity procurement with actual consumption and the emissions records supporting the figure provided to European customers.
Nemtsov’s comments highlight the difference between the availability of low-carbon generation and its use as documented evidence for industrial exports: the nuclear-heavy electricity system provides the generation characteristics, while the supporting records must establish how that electricity reaches and is consumed by the factory.

