War-Driven Transformation of Stationary Air Pollutant and Greenhouse Gas Emissions in Ukraine: Evidence from Official Statistics and Implications for CBAM and the National Emissions Trading System

Abstract

Ukraine entered the definitive period of the EU Carbon Border Adjustment Mechanism (CBAM) in January 2026 as the largest exporter of CBAM-covered goods to the EU by physical volume, while its industrial base remains under direct wartime pressure. This study provides the first structural analysis of the open microaggregated dataset of the State Statistics Service of Ukraine (SSSU) on air pollutant and greenhouse gas emissions, covering 1990–2025 across 1284 territorial units, 128 substances, and 605 economic activities (NACE/KVED-2010). A documented harmonization procedure is proposed that resolves the 2020/2021 dimensional break and the ambiguity between oblast (region)- and hromada (municipality)-level records, yielding consistent 36-year series with independent national total validation for 2015–2025. Four phases are identified: transformational decline (1990–1999, −56.5%), stabilization (1999–2013, +4.6%), post-2014 structural decline (2013–2021, −47.9%), and the full-scale war shock (2021–2025, −55.0%). Stationary source emissions fell by 89.3% overall, but the wartime reduction reflects destruction and occupation of capacity, not decarbonization, as reflected in the collapse of metallurgy (−73.8%) and coke production (−89.6%) and the loss of the Mariupol district from statistical coverage after 2022. Mobile sources now supply 65% of the national total. Coal mine methane dominates stationary CH4 (301 kt in 2021; ≈9.0 Mt CO2 eq), directly relevant to Regulation (EU) 2024/1787. The regional Herfindahl–Hirschman index fell from 1847 (2021) to 1524 (2025), indicating war-driven regional deconcentration and a westward shift in the emission center of gravity. The findings are validated against independent satellite-based and conflict attribution estimates, and implications for monitoring, reporting and verification (MRV) infrastructure, CBAM default value exposure, and the phased design of Ukraine’s emissions trading system are derived.