No Ukraine carve-out in Parliament's CBAM mandate as GMK Center models a complete export halt by 2030

The European Parliament's CBAM negotiating mandate, adopted on September 15, 2026 by 464 votes to 50 with 159 abstentions, extends the mechanism to finished steel and aluminium products and contains no Ukraine carve-out. The omission is the fourth institutional refusal since December 2025, and it lands beside the starkest modelling yet published: GMK Center, the Kyiv-based steel consultancy, calculates that CBAM adds EUR 50-100 per tonne to the cost of Ukrainian steel while the EU's new import quotas cap Ukraine at roughly 1.05 million tonnes a year, about 60 percent below what the country actually shipped in 2025, a combination its analysts model as ending Ukrainian long-product and billet exports to the EU entirely by 2030.

The story matters to three audiences: Ukrainian producers deciding whether EU-facing capacity has a future, the EU importers who buy from them, and negotiators entering trilogues with the last realistic venue for a carve-out. The full exposure picture sits in the CBAM Ukraine country guide.

What the September 15 mandate contains for Ukraine: nothing

The mandate adopted in Strasbourg on September 15 extends CBAM to finished steel and aluminium products, including fasteners, wire, springs, and household goods, and no post-vote coverage from GMK Center, EUROMETAL, or Kallanish reports any Ukraine exemption in the adopted text. Parliament rejected the Commission's proposed price-shock safety valve in favour of redirecting CBAM revenue to affected sectors, per Kallanish reporting republished by EUROMETAL on September 17. The full scope decision, the vote arithmetic, and the trilogue timetable are covered in the report on how Parliament adopted its CBAM downstream mandate 464-50.

For Ukraine, the vote converts a pattern into a record. Four institutional texts in ten months have now declined to write relief into law:

• December 2025: the Commission refused Ukraine's request for force-majeure relief under Article 30(7) of Regulation (EU) 2023/956, finding no grounds to activate the clause.
• December 2025: the Commission's strengthening proposal, COM(2025)989, contained no Ukraine exemption, per GMK Center.
• July 6, 2026: the ENVI committee's review position offered least-developed countries simplified reporting but no Ukraine provision.
• September 15, 2026: the plenary mandate extends coverage to more steel products without a carve-out.

The refusal is sharper for coming from a chamber whose rapporteur, Mohammed Chahim, had previously argued in coverage reported by GMK Center that Ukraine, as a prospective EU member, deserves special treatment to help rebuild its economy. The mandate he steered through plenary contains none.

The complete-halt forecast: EUR 50-100 per tonne meets a 1.05 million tonne cap

GMK Center models the combined effect of CBAM and the EU's new tariff-rate quotas as a complete halt to Ukrainian exports of long products and square billets, with the stop arriving as the CBAM factor rises sharply through 2029 and 2030. The forecast figures are set out in the table below.

The halt conclusion predates the quota layer. In the GMK Center study "The Impact of CBAM on the Ukrainian Mining and Metallurgical Complex and its Economy", reported by Interfax-Ukraine on March 31, 2026, analyst Andriy Tarasenko warned that "starting in 2030, Ukraine's exports to the EU are likely to be completely eliminated, which could lead to the complete closure of Ukrainian metallurgical plants." What the newer analysis adds is the quota arithmetic: since July 1, 2026, Ukraine's country-specific volumes total roughly 1.05 million tonnes a year in the covered categories, so even steel that can absorb the carbon cost has a shrinking legal channel into the market.

The per-tonne range describes the mechanism's full weight, not the 2026 cash bill. This year the CBAM factor stands at 2.5 percent, with free allocation covering the remaining 97.5 percent, so the certificate cost on a tonne of Ukrainian blast furnace steel remains in single-digit euros at current certificate prices. The EUR 50-100 range is what the escalation path delivers as free allocation phases out toward 2034, and that trajectory, not this year's cost, is what GMK Center's 2029-2030 halt is built on. Importers can model both ends of the path in the CBAM cost calculator.

A EUR 1.2 billion bill equal to two years of capital spending

GMK Center estimates cumulative CBAM payments on Ukrainian iron and steel exports at roughly EUR 1.2 billion over 2026-2030, a sum it equates to the entire capital expenditure of Ukrainian steel mills over two years, against about $650 million invested in 2024. The comparison is the point: every euro surrendered for certificates is a euro unavailable for the decarbonisation that would eventually lower the same certificate bill, at plants that GMK Center's research says cannot modernize under blackouts, security risks, and wartime logistics.

The macro projection runs in the same direction. The GMK Center study reported in March 2026 puts the mechanism's impact on Ukraine at 2.1 percent of GDP in 2030 through iron and steel alone, including supply chains, against the European Commission's own estimate of a 0.01 percent impact. The two institutions are not describing the same mechanism at different magnitudes; they are disagreeing by a factor of more than 200 about what the mechanism does to a candidate country's economy.

Who is demanding relief, and through which channel

Three demand channels are now open: trade unions, industry associations, and the Ukrainian government itself, which is negotiating with Brussels over a possible steel exemption. The record by channel runs as follows.

• Trade unions. The PMGU, Ukraine's trade union of steelmakers and miners, called for urgent solutions on CBAM exemptions in letters reported by GMK Center on March 23, 2026, addressed to Prime Minister Yulia Svyrydenko, National Security and Defense Council Secretary Rustem Umerov, EU Ambassador to Ukraine Katarina Mathernova, and IndustriALL General Secretary Atle Høie, proposing a longer transition period and support instruments for Ukrainian producers.
• Industry associations. Ukrmetallurgprom and the Federation of Employers of Ukraine formally petitioned Kyiv in August, the appeals covered when quota cuts plus CBAM triggered formal exemption demands.
• Government negotiations. Ukraine is negotiating with the EU over a possible steel-industry exemption, per GMK Center, with Deputy Prime Minister Taras Kachka involved in the discussions, after the Article 30(7) force-majeure route was closed in December 2025.
• Policy advocates. Pascal Lamy's proposal for a Ukraine CBAM exemption tied to decarbonisation milestones remains the most developed design any negotiator could lift into a trilogue text.

The measured damage backing those demands is already on record: GMK Center's half-year data showed long-product exports down 41.7 percent in H1 2026 before the new quotas even took effect.

What happens next

Trilogues on the scope extension are the last venue where a Ukraine provision could enter the package, and the institutions are targeting a deal in late 2026 or early 2027 to hold the January 1, 2028 application date. Neither co-legislator's mandate contains a carve-out, so any Ukraine text would have to be introduced during negotiations, the same route by which other unresolved items, from the final product list to the safety-valve dispute, will be settled.

For EU importers of Ukrainian steel, nothing changes today. Certificate obligations accrue against 2026 imports, certificate sales open on February 1, 2027, and the first declaration falls due on September 30, 2027. What the September 15 vote changes is the probability distribution on the supply side: absent a trilogue surprise, GMK Center's model says the material itself stops coming by 2030.