Solar Power at the Factory Gate: Ukraine’s Path Through the EU Carbon Border Levy

Ukraine’s solar industry association is urging exporters in carbon-intensive sectors to treat on-site renewable energy not merely as a cost-cutting measure but as a tool for managing liabilities under the EU’s Carbon Border Adjustment Mechanism. ASEU board chair Vladislav Sokolovsky made the case at a Dialogue Hub event, explaining that CBAM explicitly accounts for the electricity component in industries such as cement and fertiliser production.

The mechanism converts a product’s carbon intensity into a direct line item in export economics. CBAM obligations already apply to deliveries made this year, even though sales of the corresponding European certificates are not scheduled to begin until 2027. ASEU warns that the resulting costs may ultimately be borne by Ukrainian sellers through contract terms, making early preparation commercially significant.

Installing solar capacity directly on a plant’s premises creates a verifiable technical link between clean generation and production, Sokolovsky said. A physical corporate power purchase agreement may also enable a lower effective emissions factor — but only when backed by rigorous hourly consumption tracking and independent verification. “The main thing is to confirm low emissions of a specific delivery under EU rules,” he noted.

Plants pairing solar with battery storage — now roughly 80 percent of new installations — face an additional complication: distinguishing self-generated electrons stored in the battery from volumes drawn from the wider grid. Separate technical meters may be required, along with clear origin-confirmation rules, to satisfy European scrutiny.

Ukraine’s domestic guarantees of origin are not equivalent to CBAM certificates, but ASEU sees their potential EU recognition as one element of a broader decarbonisation strategy. The association is calling for pilot export deliveries to test how these approaches hold up in practice.

Source: АСЕУ