Environmental standards during wartime: how to preserve Ukraine’s industrial core?

The implementation of the European CBAM mechanism and new environmental standards is becoming a challenge for Ukrainian business operating in the extreme conditions of martial law. Is large-scale industrial modernization realistic under shelling? How to avoid the risk of deindustrialization without the systemic state support that European competitors have?
Volodymyr Shchelkunov, President of ICC Ukraine, analyzes the risks of implementing “green” norms without taking security factors into account and explains how the International Chamber of Commerce of Ukraine helps businesses adapt to new regulatory requirements while preserving the country’s production potential.

Against the backdrop of negotiations on CBAM, the topic of ecology and industrial modernization is again being actively discussed. How do you assess the new pollution norms?

New environmental norms, particularly within the CBAM mechanism, are part of European climate policy and the global course toward decarbonization. At the same time, for Ukraine, their implementation takes place under martial law, which fundamentally changes the starting conditions for industry. Some enterprises operate intermittently, some have suffered destruction or relocation, logistics are significantly complicated, and access to investment resources is limited.
Under such circumstances, environmental requirements should be evaluated not in isolation, but in combination with security, economic, and social factors. Without flexible transition periods and special regimes for a country at war, new norms can turn from a development tool into an additional pressure factor on industry.

Is it realistic for Ukraine to carry out large-scale modernization now?

In the short term — no. Under martial law, business is primarily forced to invest in survival: maintaining production, personnel, energy and physical security. It is premature to talk about full-scale modernization without completing the active phase of the war and launching recovery programs.
At the same time, it is already important to lay the foundation for future modernization: conduct an emissions audit, evaluate technological gaps with European standards, and prepare projects for participation in international reconstruction programs. This approach will allow moving from survival to development after the war ends.

Europeans received investments and grants from their governments, our industry receives nothing. Could this end in deindustrialization?

The risk of deindustrialization in war conditions and without systemic support is extremely high. European companies have been undergoing “green” transformation for decades with active state participation — through funds, grants, and compensation mechanisms. Ukrainian industry today is forced to work without such tools while performing a critical function for the economy and defense capability of the country.
If CBAM mechanisms and other environmental restrictions are applied without taking martial law into account, this could lead to production cuts, loss of export markets and jobs. That is why the issue of industrial support should be considered as an element of the state’s economic security.
ICC Ukraine is ready to continue being a platform for professional dialogue between business, the state, and international partners. We provide enterprises with consultations on CBAM requirements, carbon footprint assessment, preparation for European environmental standards, and the search for possible financial and transition mechanisms.
Under martial law, it is especially important to help business not only adapt to new regulatory requirements but also preserve production potential. Our task is to ensure that the ecological transformation of Ukrainian industry takes place gradually, economically justified, and without losing the industrial core of the country