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European Business Association

EBA

Established in 1999, the European Business Association (EBA) provides a forum in which members can discuss and find solutions to common problems affecting business in Ukraine.

Lobbying Activity

Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

26 Aug 2025

CBAM implementation creates significant risks for Ukraines economy and industries. Even before the full-scale russian invasion, Ukraine was identified as one of the countries most exposed to CBAM. The war has dramatically worsened the situation, with massive destruction of industrial and energy infrastructure, limited export corridors, logistics costs three to five times higher than pre-war levels, and severe labor shortages. These factors have sharply reduced the competitiveness of Ukrainian producers and hindered economic recovery. Around 17-20% of Ukrainian exports to the EU fall under CBAM, primarily iron, steel, cement, electricity, and fertilizers. These industries are vital for Ukraines economy, supporting jobs, local communities, and tax revenues, while ensuring integration into EU value chains. Maintaining access to the EU market is therefore critical for Ukraines resilience. However, CBAM is expected to lead to export losses of $4.6 billion between 2026 and 2030, with annual losses reaching $1.4 billion by 2030. The steel sector alone, accounting for 93% of CBAM-exposed exports, could lose $1.3 billion. Cement exports are projected to become uncompetitive, adding about 10 million in costs per 1 million tons exported. Beyond direct losses, GDP could decline by up to $4.9 billion by 2030. Ukraines ability to respond is constrained by war. Direct infrastructure losses already amount to $170 billion. Industrial activity has been severely reduced, while enterprises struggle with higher costs and limited capacity to recover. This clearly constitutes an unforeseeable, exceptional and unprovoked event as defined in Article 30(7) of the CBAM Regulation, which allows for provisional measures in such cases. EBA therefore calls on the European Commission to: 1. Introduce a temporary CBAM exemption for Ukraine for the duration of martial law and a defined post-war recovery period (5 years). 2. Develop a practical mechanism for the application of Article 30(7) to address exceptional circumstances caused by external aggression. Ukraine is committed to alignment with EU environmental and climate objectives and the European Green Deal. However, extraordinary wartime conditions require flexibility to preserve Ukraines industrial base, safeguard jobs, and sustain EU-Ukraine trade flows. Tailored CBAM measures will allow Ukraine to maintain resilience now and contribute more effectively to decarbonisation and EU integration once recovery is possible.
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and

4 Jun 2025 · Exchange on CBAM implementation and application to imports from UA and customs cooperation.

Response to Further reciprocal tariff liberalisation under Art. 29 of the EU-Ukraine Association Agreement

30 Sept 2024

The European Business Association (hereinafter referred to as the "EBA") acknowledges its respect to you and addresses the following. The EBA is one of the largest business associations in Ukraine. The EBA is reaching out to you in response to the Call for Evidence regarding the review of the Association Agreement between Ukraine and the EU concerning mutual tariff liberalization, and we wish to provide the following comments. Since January 1, 2016, the Deep and Comprehensive Free Trade Area (DCFTA) between Ukraine and the EU has been in effect under the Association Agreement, which provides for mutual trade liberalization. For most goods, the Agreement established transitional periods, after which zero duty rates should be applied. As of today, all transition periods have expired. Consequently, the only tariff restrictions currently provided by Annex 1A of the Association Agreement are the tariff quotas for 36 categories of goods and the application of entry price systems for some goods. In June 2022, following unprovoked and unjustified full-scale invasion of russian federation, which posed an enormous challenge to Ukraine, the EU introduced temporary trade liberalization measures for Ukraine. These temporary measures cover all goods previously subject to tariff restrictions (tariff quotas and entry price systems) under the Association Agreement. On May 14, 2024, the European Parliament and the EU Council adopted Regulation No. 2024/1392, which extended these temporary trade liberalization measures until June 6, 2025. The parties agreed that this extension would be the final one, and Ukraine and the EU must develop a new trade liberalization mechanism under the Association Agreement. The EBA members fully support the need to review the trade liberalization regime and consider this task critically important to ensure the interests of businesses in both Ukraine and the EU. Firstly, Annex 1A of the Association Agreement initially listed goods with reduced tariff rates and transition periods after which zero tariffs will be established. As of today, zero tariff rates are applied to most goods (except those subject to tariff quotas and entry price systems). Therefore, the EBA members consider it appropriate to revise the trade liberalization regime and, within the framework of the Association Agreement, define only those goods for which tariff restrictions will apply. Secondly, from 2016 to 2024, significant economic convergence has taken place between Ukraine and the EU. For example, the trade volume increased from $29.5 billion in 2016 to $55.9 billion in 2023 . This was driven by economic growth, Ukraine's accelerated integration into the EU, the refusal of trade with russia, and integration into other markets. Since the full-scale invasion by russia, the EU market has become the primary trade direction for Ukraine. Currently, the share of Ukrainian exports to the EU constitutes around 66% of Ukraine's total exports. Ukraine has also become an important trading partner for the EU (ranked 17th in importance). Regarding agricultural products, Ukraine is among the top three suppliers to the EU market2. Therefore, the return of restrictions that existed until June 2022 will have a critical negative impact on the economy of Ukraine. At the same time, such restrictions will also harm EU business representatives. Thirdly, the increase in imports of Ukrainian products to the EU does not harm the internal EU market. Specifically, the temporary trade liberalization regime introduced in June 2022 provides for the European Commission to monitor the impact of Ukrainian products on the market. From 2022 to 2024, the European Commission did not identify any signs of such negative impact. Moreover, Ukraine has demonstrated its readiness to strictly adhere to the established restrictions and not violate the requirements of the trade liberalization regime. Ukraine also takes preventive measures on its own to avoid any negative impact on the
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Meeting with Valdis Dombrovskis (Executive Vice-President) and Federation of Employers of Ukraine

8 Mar 2024 · EU-Ukraine trade relations, Ukraine Facility – possibilities for business.

Response to The reporting obligations during the transitional period of the carbon border adjustment mechanism.

11 Jul 2023

Please find attached a feedback from the European Business Association, leading business community in Ukraine.
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Meeting with Nicola Beer (Member of the European Parliament)

13 Apr 2023 · Business in Ukraine (held by parliamentary assistant)

Meeting with Gert Jan Koopman (Director-General Enlargement and Eastern Neighbourhood)

22 Mar 2023 · EU/Ukrainian businesses

Meeting with Nicola Beer (Member of the European Parliament)

1 Mar 2023 · Business in Ukraine