Ukraine · Exporter · CBAM
Ukrainian exporters across four CBAM sectors: one XML pipeline
Under the EU Carbon Border Adjustment Mechanism, Carbon Mandate prepares the declaration data as machine-readable XML from verified embedded-emissions data across Ukraine’s in-scope sectors, led by iron & steel, with fertiliser chemistry close behind. We do not file — the importer files.
Reg (EU) 2023/956 Annex I · IR (EU) 2025/2620 · IR (EU) 2025/2621
Ukraine
4 sectors in scope
UA nuclear and mixed-generation grid
Sector exposure: four goods classes
Ukraine’s dominant CBAM-exposed export class: pig iron, semi-finished and finished steel under Chapters 72 and 73 supplying EU mills and processors.
Ammonia, nitric acid, urea and NPK fertilisers under Chapters 28 and 31. A long-standing Ukrainian export where precursor chemistry drives the declared figure.
Primary and secondary aluminium under Chapter 76. Embedded emissions turn on the smelting route and the origin-grid factor.
Calcined clays, cement clinker, Portland and hydraulic cements under Chapter 25 (2507 · 2523). Clinker is the emission-dominant precursor.
CN scope per Annex I to Regulation (EU) 2023/956. One declaration pipeline covers all four classes: each goods line carries its own emissions basis, compiled into machine-readable CBAM XML and checked against the declaration structure the Commission has specified. The Commission has not yet published a definitive annual-declaration XSD. We produce an XML declaration with the full precursor chain intact, not a PDF report or a spreadsheet template.
Indirect emissions: Ukrainian grid intensity
Ukraine’s large nuclear share means the origin-grid factor is materially lower than a coal-weighted peer.
Across all four sectors, indirect emissions follow the carbon intensity of the electricity consumed in production. For Ukrainian installations that is the national grid, which carries a large nuclear share alongside thermal and hydro generation, not a blanket EU default. The XML captures the origin-grid figure for the electricity actually drawn, so the declared embedded emissions reflect where the goods were made.
Where an installation cannot evidence an actual electricity emission factor, the declaration falls back to the origin-country grid factor under Annex III to Commission Implementing Regulation (EU) 2025/2621, a per-country value, never a single product default.
Live demonstration
See the XML prepared live — in 20 minutes
No slides. No sales pitch. We open a live CBAM file from your sector, run the same checks we run on every declaration, and show you the XML file we produce.