According to the Trade Union of Metallurgists and Miners of Ukraine (PMGU), introducing CBAM on standard terms could be a "crushing blow" for a country that has been resisting Russian aggression for four consecutive years. Operating under active combat conditions, broken supply chains, and a total labor shortage, Ukrainian industry lacks the resilience to cope with the immediate implementation of such regulations. For sectors like the mining and metal complex (MMC), which has lost approximately 40% of its capacity due to the war, the task is considered insurmountable.
First Consequences: Production Halts at ArcelorMittal Kryvyi Rih
The looming application of CBAM during a full-scale war threatens jobs and increases social tension in frontline strategic cities, including Zaporizhzhia, Nikopol, Pavlohrad, Kryvyi Rih, and Dnipro.
The first practical consequences have already emerged: last week, ArcelorMittal Kryvyi Rih (AMKR) announced the forced shutdown of its blooming mill shop in the rolling department.
"The main factor behind AMKR's decision to halt the blooming mill in the second quarter of 2026 was the European Commission's decision to implement CBAM from January 1, 2026, without considering the objective economic and market circumstances in which Ukrainian producers operate during wartime," stated Natalia Marynyuk, head of the local PMGU primary organization.
Economic Risks and the Loss of Competitiveness
The implementation of CBAM during martial law poses a severe threat to Ukrainian metallurgy, which is export-oriented and carbon-intensive. Key risks include:
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Cost Increases: Additional costs for CBAM certificates are estimated at $60–$90 per ton, rendering products uncompetitive against European or lower-carbon producers.
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Loss of Orders: European clients have already halted orders, leading to a projected loss of 1.25 million tons of exports for AMKR in 2026 alone.
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Macroeconomic Impact: Potential production halts will lead to job cuts, a decrease in GDP, and reduced tax revenues for the state budget.
Appeal for the "Force Majeure" Clause
Unions point out that the European Commission has not yet utilized Article 30.7 of CBAM Regulation (EU) 2023/956. This clause allows for the deferral or adjustment of the mechanism for countries affected by "unforeseeable, exceptional, and unprovoked events" that cause serious damage to economic and industrial infrastructure.
The PMGU argues that this provision is the intended tool to exempt Ukrainian exports from CBAM for the duration of martial law. Without a grace period, the industry faces the risk of shutting down blast furnaces and subsequent mass layoffs.
Union Demands
The initiative is supported by the Federation of Trade Unions of Ukraine (FPU) and unions representing the coal, chemical, energy, and construction materials sectors. In their letter to Ambassador Mathernová, they called for:
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An extension of the transition period for Ukraine.
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The creation of special financial aid funds for industrial re-equipment.
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The inclusion of trade union representatives in the dialogue regarding the practical implementation of the mechanism.
Currently, the PMGU is consulting with AMKR management to arrange retraining and internal relocation for employees affected by the shop closures, aiming to preserve skilled personnel amidst the national labor crisis.
