Ukrainian cement producers require equal conditions with their European counterparts in the implementation of the Carbon Border Adjustment Mechanism (CBAM) from 2026.
“While EU companies have support and equal conditions for investments in decarbonization, Ukrainian companies do not have such support. During martial law, the cost of CBAM certificates puts Ukrainian exports at a disadvantage compared to EU producers and creates additional obstacles for Ukrainian enterprises, exacerbating the negative consequences of the war,” said Lyudmila Krypka, executive director of the Ukrcement Association, on Wednesday during the event “CBAM and the readiness of Ukrainian industry for decarbonization: from methodology to competitive advantage,” organized as part of the STEP IN 2 EU program.
She reminded that Ukraine does not have developed financial markets that would allow it to attract funding for decarbonization. Instead, there are challenges and barriers, one of which is the war and constant round-the-clock rocket and drone attacks, destroyed energy facilities, including generation, staffing problems due to mobilization and emigration, and much more.
As reported, on December 17, 2025, the European Commission (EC) took measures to strengthen the effectiveness of the Carbon Border Adjustment Mechanism (CBAM). From 2026, updated, stricter benchmarks will come into force and a surcharge will be applied to the default values: 10% (2026), 20% (2027), and 30% (from 2028).
According to the expert, to ensure transparency and meaningful participation of all relevant stakeholders, it is important to review the default values as early as 2026, as the values proposed for Ukraine range from 1,500 to 1,794, which are several times higher than the actual figures.
Thus, actual CO2 emissions in the 1990s amounted to 0.956 kg, provided that a larger number of enterprises in the industry (up to 15 enterprises) were operating and production amounted to 17-18 million tons; from 2017 to 2020, emissions decreased from 891 to 879 kg (production decreased from 6,333 to 7,419 thousand tons, the number of enterprises was 10). According to forecasts, in 2025, emissions will be around 0.700 kg, not 1,500.
“The production of 1 ton of cement clinker emits approximately 850 kg of CO2. When using alternative fuels, 90% of CO2 emissions will amount to 672 kg/1 ton of clinker,” Kripka gave an example.
Unfortunately, she added, the alternative fuel market in Ukraine is not working, and Ukrainian cement producers buy it in the EU. Over the past two years, cement companies have been using 20 to 30% alternative fuels, with the goal of increasing the share of alternative fuels to 40% by 2030.
Ukrcement has made a number of proposals to level the playing field for Ukrainian companies subject to the ETS. First of all, our producers should receive free quotas similar to those in the EU; the tax should be applied to actual emissions rather than default values; Ukrainian legislation needs to be harmonized with EU rules on biomass taxation. It is also necessary for producers to be able to use tax “environmental” payments to decarbonize their own enterprises. Cooperation with European verifiers and training courses on CBAM calculation are important.
The Ukrcement Association was established in January 2004 through the reorganisation of the Ukrainian Concern of Cement Industry Enterprises and Organisations “Ukrcement”. The association has four members, comprising eight enterprises that meet 100% of the domestic Ukrainian market’s cement needs.
The Ukrainian cement market has stabilized after sharp fluctuations in 2021–2023, but production volumes remain almost half of what they were before the war. This is stated in an analysis by Experts Club, prepared in collaboration with the Ukrcement association.
In 2021, cement production reached 11 million tons, fell to 5.4 million tons in 2022, recovered to 7.43 million tons in 2023, and to 7.93 million tons in 2024. According to manufacturers’ estimates, the “ceiling” in 2025 will be around 8 million tons.
Consumption: 10.6 million tons in 2021, 4.5 million tons in 2022, 6.2 million tons in 2023, and 6.3 million tons in 2024. Thus, the market has stabilized at 6–6.5 million tons, which is about half of pre-war demand.
The structure of demand has changed: instead of residential and commercial construction, infrastructure and defense projects dominate — fortifications, shelters, urgent repairs of roads and bridges. Demand is additionally supported by state programs, including “єОселя.”
In 2025, experts expect stable “military” demand to continue, sensitive to budget financing and donor assistance.
Experts Club is a Ukrainian analytical center specializing in research on economics, energy, macroeconomics, infrastructure, and export-import relations.
A condensed version of the Experts Club’s cement market study is available at https://expertsclub.eu/rynok-czementu-ukrayiny-doslidzhennya-experts-club/
The Ukrcement Association brings together Ukraine’s leading cement producers.
The Experts Club information and analytical center, with the assistance of the Ukrainian Cement Manufacturers Association (Ukrcement), has conducted an analysis of the Ukrainian cement industry.
Over the past five years, the Ukrainian cement industry has experienced a peak in production in 2021, a sharp decline in 2022, a gradual recovery in 2023, and stabilization in 2024. However, the current level is still far from pre-war indicators.
According to trade union and industry reviews, output was about 11 million tons in 2021, fell to 5.4 million tons in 2022, recovered to 7.43 million tons in 2023, and reached 7.93 million tons in 2024. In 2025, manufacturers are talking about an actual “ceiling” — approximately 8 million tons under current risks and logistics, which is likely to be the maximum figure.
The dynamics of domestic cement consumption show a similar trend of “decline and normalization.” In 2021, before the full-scale invasion, consumption was around ~10.6 million tons. In 2022, the cement market fell sharply to approximately 4.5 million tons, rose to 6.2 million tons in 2023, and stabilized at around 6.3 million tons in 2024. Thus, the country approached a stable level of “war” demand, which is almost half of the pre-war level, within the range of 6–6.5 million tons.
The structure of demand has changed: the share of traditional residential and commercial construction has given way to infrastructure and defense projects. The key short-term drivers are fortification works, shelters, emergency repairs of roads and bridges, as well as targeted housing programs such as “єОселя,” which supported demand in 2023–2024, although they did not return it to the 2021 level. The market expects demand to remain stable in 2025, sensitive to the volume of budgetary and international financing.
Amid declining domestic demand, a natural step to support production capacity utilization was the gradual reorientation of part of the cement output to foreign markets. In 2021, cement exports amounted to about 971,000 tons (9% of production), and in 2024, about 1.7 million tons (21.3% of production). The main destinations remain neighboring countries—Poland, Romania, Hungary, and Moldova—as confirmed by both statistical data and industry estimates. The industry has repeatedly emphasized that as soon as domestic consumption begins to grow, the export share will decline in favor of Ukrainian construction sites.
Imports, on the contrary, have declined. After approximately 1 million tons in pre-crisis 2020, deliveries in 2024 decreased to ~40 thousand tons (including niche items such as white cement). This was also influenced by anti-dumping duties: against Turkey — 33–51% (in effect until September 2026), and against Russia/Belarus/Moldova, measures have been extended until 2030. Under the current conditions, when production capacities and logistics are adapted to the “military” level of consumption, demand is fully covered by domestic resources.
The market structure in 2024–2025 is highly concentrated. The key producers are PJSC Ivano-Frankivskcement, the CRH group (after the AMCU approved the deal to acquire CRH’s Dyckerhoff/Buzzi assets — PJSC VIPCEM, Podolsky Cement JSC, Mykolaivcement PJSC, Cement LLC) and Kryvyi Rih Cement PJSC. Despite market discussions, legal disputes, and attention from antitrust authorities—which is to be expected for transactions of this scale—the CRH deal creates potential for integration into global production and logistics chains, attracting new investments, modernizing production, and raising the standards of the competitive environment. In the context of the country’s future large-scale recovery, the agreement opens up opportunities to strengthen supply stability, improve product quality, and develop a competitive environment.
Who is currently driving domestic consumption? In peacetime, the main stabilizers of demand were mass housing construction and infrastructure. In 2023–2025, basic demand will be driven by roads and engineering structures (including fortifications and shelters), municipal and energy facilities, selective reconstruction projects, as well as the private sector — repairs and local construction.
Road construction is an important factor in economic and social development. The introduction of the latest technologies, the use of high-quality materials, and compliance with environmental requirements are key aspects of the successful development of this industry.
The development of the construction and repair of cement concrete roads based on cement mixtures can play a key role in stimulating stable cement consumption in conditions of war and reconstruction. This infrastructure direction makes it possible to maintain the production capacity of enterprises, jobs, and economic activity, despite a significant reduction in residential and commercial construction. Thanks to their durability and endurance, cement concrete pavements are the optimal solution for both military and civilian logistics. The implementation of such projects not only ensures constant demand in the industry, but also the development of related sectors, creating a multiplier effect for the economy even in crisis conditions. This issue will be the focus of a specialised seminar organised by NIRI and the Ukrcement Association on 15-16 October 2025, where the advantages and role of cement concrete solutions in the reconstruction of Ukraine will be discussed (details at ukrcement.com.ua).
In terms of sales channels, the market remains predominantly B2B: most of the cement is purchased by contractors, road and infrastructure companies, large developers, reinforced concrete manufacturers, and concrete plants. The B2C channel (retail chains of building materials, small contractors) continues to play a significant role in repairs and low-rise construction, but in terms of total volume, it is inferior to the project segment. Industry reviews of construction projects and reports on fortification works in 2024–2025 provide further confirmation of the “infrastructure” shift.
The geography of foreign sales shows a stable “corridor” and proximity to the EU. According to trade statistics for 2023, Romania accounted for the largest value of supplies, followed by Poland and Hungary; in 2024, Romania, Poland, and Hungary remained in the lead.
This reflects shortages in the EU border markets and the competitiveness of Ukrainian prices with close logistics.
What limits growth. Military risks and energy infrastructure (in particular, the availability of electricity), regional logistics, as well as regulatory and competitive issues. A large-scale jump in consumption (approximately 12–13 million tons) requires a steady inflow of investment resources for reconstruction of around $35 billion per year — the association considers such a scenario to be technically and operationally realistic. Predictable competition rules and price monitoring are important in the equation so that the “reconstruction” multiplier is not absorbed by costs.
Conclusion by Experts Club. The industry has found a “military balance”: production of about 8 million tons, domestic consumption of ~6.3 million tons, and exports as insurance at the level of 1.5–1.7 million tons. With the scaling up of energy restoration and strengthening programs, a shift from exports to the domestic market is logical. The key to acceleration is stable financing of infrastructure and housing, affordable energy, and maintaining fair competition between major players. In such a scenario, cement remains one of the first materials that quickly transforms the budget into employment and GDP — through concrete, reinforced concrete structures, roads, and fortifications.
Sources: Global Cement (production and consumption; import duties), Interfax-Ukraine/Ukrcement (exports in 2024; estimates of reconstruction needs), OEC (export destinations in 2023), CEMBUREAU (imports, exports, and consumption, in particular the benchmark for 2024), industry and business media regarding the CRH/Dyckerhoff deal and the competitive situation.
Source: https://expertsclub.eu/rynok-czementu-ukrayiny-doslidzhennya-experts-club/
As part of anti-dumping investigations, duties are more effective for economic development, according to Pavlo Kachur, head of Ukrcement.
“There are two mechanisms for protecting the market: anti-dumping duties and price proposals. The difference between them is that the additional delta that equalizes prices in one case goes to the domestic budget, and in the other case goes to the foreign producer. In today’s situation, when every hryvnia of revenue to the state budget is very important, when this hryvnia is used for defense, when domestic consumption in Ukraine has fallen significantly, the mechanism of anti-dumping duties is much more patriotic, because it additionally fills the state budget,” he told Interfax-Ukraine on the sidelines of the conference ‘Trade Wars: The Art of Defense’ in Kyiv on Tuesday.
Kachur stressed that protecting the interests of Ukrainian producers in wartime is not only the right but also the duty of the state.
As reported, the Interdepartmental Commission on International Trade (ICIT) is reviewing anti-dumping measures on imports of cement from Russia, Belarus, and Moldova to Ukraine in connection with the expiration of their validity. Earlier, in 2019, the ICIT imposed anti-dumping duties on imports of cement clinker and Portland cement under codes 2523 10 and 2523 29 to Ukraine at the following rates: 57.03% on cement from Belarus; 94.46% on cement from Moldova; 114.95% on cement from Russia. The duties were imposed for a period of five years and extended for one year in 2024.
https://interfax.com.ua/news/economic/1073234.html?utm_source=telegram
The National Association of Extractive Industries of Ukraine, Ukrmetallurgprom, the Ukrainian Association of Ferroalloy Producers (UkrFA), the All-Ukrainian Union of Construction Materials Producers, and Ukrcement ask President Volodymyr Zelenskyy to instruct the ministries to promptly resume booking employees through the Diia portal.
“We understand and share the president’s desire to put things in order with the booking of workers. However, against the backdrop of questionable decisions by local authorities, the relevant ministries have also completely suspended the booking process,” the letter, which was seen by Interfax-Ukraine, reads.
Its authors recognize that the current reservation procedure is not perfect and contains certain flaws that allow companies that are not in fact critical enterprises to be granted the status of critical enterprises. However, in the associations’ opinion, it is primarily a matter of the possibility of obtaining such a status by decision of local state (military) administrations.
At the same time, the letter states, following a meeting held in early October and the Cabinet of Ministers’ decision to audit the decisions made on reservations, some ministries also suspended the reservation process, although it was declared that this decision did not apply to them. According to the associations, these ministries have completely suspended the processes of confirming the status of critical enterprises and booking employees for truly important enterprises that have already received this status from the relevant ministry. In addition, the possibility of booking employees through the Diia portal has been suspended until November 15.
“We are confident that your instructions were aimed at identifying risks and shortcomings for their further elimination, but were not intended to stop all processes of booking personnel for truly critical enterprises, which could completely stop the economy and lead to catastrophic consequences,” the letter says.
As reported, after the government’s protocol decision of October 8 to audit decisions on recognizing enterprises as critical to the economy, the booking process was effectively paralyzed, which caused protests from many business associations.
On October 22, the government introduced the possibility of repeated audits of companies’ compliance with the criteria of critical importance “if necessary.” The document stipulates that these inspections are to be conducted by the same authorities that initially granted the companies the status of critical. The result of such an audit may be that the company does not meet the criteria of a critical enterprise and that its status is revoked. The authorities must provide a copy of the decision based on the results of the re-inspection to the Ministry of Economy, the Ministry of Defense (the SBU, the Foreign Intelligence Service, the intelligence agency of the Ministry of Defense) and the Ministry of Digital Transformation within one day.
employee, reservations, UKRCEMENT, UKRMETALLURGPROM, ZELENSKY, УкрФА
In January-March 2024, companies belonging to the Ukrcement association increased cement production by 46.3% compared to the same period in 2023, up to 1 million 477.9 thousand tons of cement, the Ukrcement press service reports.
According to the association, the figure for January-March this year almost reached the same period in pre-war 2021, when the volume of cement produced amounted to 1.56 million tons.
At the same time, clinker production in the first quarter of 2024 decreased by 8.5% compared to the first quarter of last year and amounted to 878.5 thousand tons.
As reported, in 2023, the total volume of cement produced in Ukraine increased by 37% compared to the previous year and amounted to 7.4 million tons.
The Ukrcement Association was established in January 2004 through the reorganization of the Ukrainian Concern of Enterprises and Organizations of the Cement Industry Ukrcement. The Association comprises five groups of companies including nine cement enterprises.
