The Council has specified the list of products concerned, while the European Commission will receive a mandate to review and potentially expand this list on an annual basis.
According to estimates by the European Commission, the proposed expansion could add an further 2.5% of EU imports to CBAM’s scope. As a result, the mechanism would go beyond basic materials to cover a significant share of industrial products and manufacturing value chains.
For Ukrainian exporters, the expansion of CBAM may result in additional product categories becoming subject to its requirements. As noted by Oleksandr Baskov, Manager, Sustainability and ESG at KPMG in Ukraine, although the European Commission considers the overall impact of adjustment mechanism on Ukraine’s economy to be manageable, the implications could be significant for certain large enterprises, as well as many small and medium-sized businesses operating in specific sectors. According to Oleksandr, extending the mechanism to downstream products broadens the range of goods that could potentially fall within its scope, including a wider and less obvious range of products that contain raw materials or intermediate inputs that are already covered by CBAM. Keeping this in mind, Ukrainian manufacturers should closely monitor further regulatory developments in the EU and proactively assess how future CBAM requirements may affect their products and overall market access.