Pascal Lamy, the former EU trade commissioner and ex-Director-General of the World Trade Organization, has become the highest-profile voice yet to call for a Ukraine CBAM exemption. In an interview with the French policy outlet Contexte, given on July 22, 2026 and reported more widely on July 29, Lamy argued that Ukraine should be exempted from the Carbon Border Adjustment Mechanism, with relief conditioned on specific decarbonisation milestones linked to the country's EU membership bid.
The intervention lands three weeks after the European Parliament's environment committee declined to include a Ukraine exemption in its CBAM review position. It matters to three audiences: Ukrainian steel and electricity exporters absorbing the mechanism's commercial pressure, the EU importers who buy from them, and policy watchers tracking whether the autumn trilogues reopen a question Brussels has so far answered with no.
What Lamy said, and where he said it
Lamy told Contexte that Ukraine should be exempted from CBAM because Ukrainians are "being hit in two of their major exports to the EU", steel and electricity. The interview was given on July 22 and published by Contexte, with wider pickup following on July 29 through trade outlets including Eurometal and GMK Center. Lamy served as EU trade commissioner before running the WTO, and he currently coordinates the Jacques Delors network of think tanks.
One disclosure belongs next to his argument. Lamy sits on the supervisory board of DTEK, the Ukrainian energy company, a seat that the coverage of the interview notes and that readers should weigh when assessing an intervention touching Ukrainian electricity exports. Even with that caveat, his voice changes the register of the debate. Eurometal notes that several MEPs and a trade association had already called for a Ukraine exemption; none carries the institutional weight of a former trade commissioner who ran the global trading system for eight years.
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A conditional exemption anchored in EU accession
Lamy proposed a conditional exemption, not a blanket one: CBAM relief granted in exchange for Ukraine meeting specific decarbonisation milestones tied to its EU membership bid. The design addresses the paradox at the centre of Ukraine's position. As an accession candidate, Ukraine is expected eventually to join the EU Emissions Trading System, at which point CBAM would no longer apply to Ukrainian goods at all. The CBAM Ukraine country guide maps that accession complication in full: the short-term burden of certificate costs and the long-term promise of ETS membership pull in opposite directions, and a milestone-linked exemption would bridge the interim without abandoning the mechanism's climate logic.
The proposal also differs structurally from the concessions Brussels has been willing to make. The ENVI position adopted on July 6, 2026 offers least-developed countries simplified reporting and a technical assistance framework, treatment examined in the guide to CBAM and developing countries. Ukraine is neither a least-developed country nor an ETS-linked country like Switzerland, so it falls between the two categories that current CBAM design accommodates.
The numbers behind the pressure: both flagship exports face losses above 60 percent
Ukrainian long steel exports to the EU fell more than 60 percent year-on-year in the first quarter of 2026, per GMK Center reporting, and Bruegel research estimates that CBAM could cut Ukrainian electricity exports by more than 60 percent. The table below sets out the reported figures and their sources.
| Indicator | Reported figure | Attribution |
|---|---|---|
| Ukrainian long steel exports to the EU, Q1 2026 | Down more than 60% year-on-year | GMK Center reporting |
| Ukraine's rank among CBAM-covered steel suppliers to the EU, end-2025 | Largest by volume | Eurometal |
| Projected cut to Ukrainian electricity exports under CBAM | More than 60% | Bruegel research |
| Projected Ukrainian export losses, 2026-2030 | $4.7 billion | GMK Center 2024 study |
The steel figure reflects combined pressures: war damage to production capacity and the arrival of certificate costs on the EU side. The 2026 cost itself is still modest, because the CBAM factor stands at 2.5 percent while free allocation covers the remaining 97.5 percent. At the Q2 2026 certificate price of €75.28/tCO₂e, a tonne of blast furnace steel with roughly 2.0 tCO₂ of embedded emissions carries about €3.76 in certificate cost this year. What worries Ukrainian producers is the escalation: that factor rises every year until free allocation disappears in 2034, and the strategic options by production route are set out in the guide for steel exporters to the EU.
Electricity is the second front. Ukraine's grid synchronized with ENTSO-E in March 2022 and exports power to the EU through interconnectors, but the country does not qualify for the electricity exemption available to fully coupled markets, so its coal- and gas-heavy generation mix is priced through the rules explained in the CBAM electricity guide. Bruegel's estimate of a 60 percent-plus export cut is an analyst projection, not an observed outcome, but observed data from the region points the same way: the Energy Community reported that EU-Western Balkans power trade fell 15% in Q2 as CBAM reshaped flows.
What Brussels has refused so far
The Commission refused Ukraine force-majeure relief in December 2025, and the ENVI position adopted on July 6, 2026 contains simplified reporting for least-developed countries but no Ukraine exemption. Lamy's proposal therefore arrives against a record of three refusals in eight months:
- In December 2025, the Commission declined Ukraine's request for force-majeure relief from the definitive regime that started on January 1, 2026.
- The Commission's December 2025 review considered a Ukraine-specific exemption and did not grant one, citing limited aggregate economic impact, a framing Ukrainian industry disputes given that steel dominates the country's CBAM-covered exports.
- The ENVI committee's CBAM review position, adopted 56 votes to 11, included no Ukraine carve-out, even though pre-vote drafts reported by Eurometal had floated default-value flexibility for candidate countries facing security situations.
The pattern is consistent: each institution has acknowledged Ukraine's situation and each has stopped short of writing an exemption into legal text.
Why the autumn trilogues are the next test
Lamy's intervention keeps the Ukraine carve-out alive as a question for the autumn trilogues on the CBAM review, which begin after the September plenary vote fixes Parliament's negotiating mandate. Trilogues are where the open numbers get settled, from the product list of the CBAM downstream expansion to the fate of the deleted emergency brake, and a Ukraine provision could enter the package there even though neither co-legislator's position currently contains one.
Two dynamics improve the odds compared with July. First, a former trade commissioner publicly framing the exemption as milestone-conditional gives negotiators a design that answers the standard objection that any carve-out unravels CBAM's WTO-defensible uniformity. Second, the EU is already showing flexibility toward third countries through other channels: the India-EU FTA now contains a dedicated CBAM annexure with a work plan, evidence that accommodation can be structured rather than ad hoc.
For exporters and importers, nothing changes today. Ukrainian steel and electricity remain fully covered, certificate obligations accrue against 2026 imports, and the first declaration falls due on September 30, 2027. The CBAM Ukraine guide tracks the exemption question, and this site will report whether the trilogue texts pick up what Lamy has put on the table.