Green Deal Ukraїna Contributes to CBAM Consultation on Electricity Trade
Green Deal Ukraїna has submitted its views to the European Commission’s public consultation on the Carbon Border Adjustment Mechanism (CBAM), focusing on specific challenges in the electricity sector.
The submission highlights that the current regulations, particularly the reliance on default emission values, could impede electricity trade with Energy Community countries, including Ukraine.
These regulations may also hinder investment in clean energy and market integration. However, preliminary modelling results indicate that the risk of carbon leakage in this sector is relatively limited (GDU, forthcoming). To address these challenges, GDU suggests extending the transitional period for electricity until 2028 or alternatively adapting exemption conditions under Article 2(7) so that countries progressing towards EU market coupling can obtain an exemption by 2026. Such adjustments would provide time to develop more accurate methodologies for dynamic (e.g. hourly) default emission values and ensure that CBAM supports both carbon reduction goals and regional energy integration. Furthermore, it is also suggested to exclude certain non-commercial TSO-TSO exchanges from CBAM such as emergency assistance and the settlement of unintended deviations.
Please find the full consultation contribution here https://greendealukraina.org/