Ukrainian employers are calling for a wartime deferral of European Union CBAM payments for steel and tube producers, while retaining emissions-reporting obligations for exporters to the EU.
Ruslan Ilyichov, chief executive of the Federation of Employers of Ukraine, made the proposal in an opinion article published on 2 October, arguing that CBAM should remain a priority in government discussions with Brussels. His approach would separate the requirement to report embedded emissions from the timing of the related certificate payments.
Steel exporters face overlapping market constraints
The request comes as Ukrainian manufacturers continue to operate amid wartime disruption. Ilyichov referred to Centravis, a stainless-steel tube producer, and Interpipe, a producer of pipes and railway wheels, in outlining the combined challenges linked to European market access, carbon calculations and trade restrictions.
Under the proposal, force-majeure provisions would be used to postpone CBAM payments rather than remove the emissions-reporting system. The measure remains an industry request and does not establish an EU exemption for Ukrainian exporters or confirm that their shipments qualify automatically for payment relief.
CBAM financial obligations remain separate from reporting
The EU’s CBAM entered its definitive phase on 1 January 2026. Its financial obligations apply to covered imports and operate alongside requirements concerning authorised declarants and emissions information.
A political request from Ukrainian industry does not alter the rules currently applicable to importers. Any change to the payment obligation would therefore require an adjustment to the relevant EU legal framework rather than resulting automatically from the proposed wartime arrangement.
Retaining reporting requirements while deferring payments would also preserve the underlying emissions-data process. Producers would still have to identify relevant installations, establish the emissions associated with their goods and provide usable information to European customers.
Payment deferral would not remove CBAM preparation requirements
For Ukrainian producers, the proposed concession would therefore target cash exposure rather than eliminate CBAM compliance work. Emissions evidence would continue to be required even if the financial charge were postponed.
That distinction is also relevant to European buyers of Ukrainian steel and tube products. A requested payment holiday does not amount to a confirmed reduction in the landed cost of imports.
Until Brussels changes the applicable legal position, contracts and purchasing decisions cannot treat the Ukrainian industry’s proposal as an exemption from CBAM payments.
