On Friday, June 6, a renewed trade regime between Ukraine and the European Union came into effect. It replaces the Autonomous Trade Measures (ATMs), which expired on June 5, and serves as a "bridge" toward a new version of the Deep and Comprehensive Free Trade Area (DCFTA) envisaged in the Association Agreement, which is currently being negotiated between Ukraine and the EU.

The new conditions were discussed during an international online webinar organized by UCAB. According to Oleksandra Avramenko, Head of the European Integration Committee UCAB, the worst-case scenario was avoided: there was no abrupt return to the 2021 restrictions. Instead, a transitional regime was introduced, partially restoring quotas on nearly 30 product groups. These new quotas will apply from June 6 to December 31, 2025, and will amount to 7/12 of the annual volumes established by the Association Agreement, since seven months remain until the end of the year.

How does it work?

From now on, tariff quotas are reinstated for a range of products, including wheat and its processed products, barley, corn, beef, pork, milk and cream, powdered milk, butter and milk fats, eggs and poultry meat, tomato paste, garlic, and others. If export volumes exceed the specified thresholds, exporters will be required to pay duties in accordance with the tariffs set by the Association Agreement (DCFTA).

It is important to note that the new quotas significantly restrict access for Ukrainian products compared to the almost full liberalization under the ATM regime. At the same time, imports within the quota limits remain duty-free.

Quota allocation follows the principle of “First Come – First Served.” For some products, additional sub-periods have been introduced – “June–September” and “October–December” – to ensure the even distribution of supply throughout the year.

What are the consequences?

According to preliminary estimates by UCAB, Ukraine's economy may lose around €1.1 billion by the end of 2025. This is less than the €3.3 billion projected in the case of a full return to 2021 rules, but it still poses a serious challenge for Ukraine’s agricultural sector and the economy as a whole.

The changes will hit small and medium-sized farmers particularly hard. They account for up to 75% of Ukraine’s agricultural sector and often operate in the regions most affected by the war, including Sumy, Chernihiv, Kharkiv, Kherson, Mykolaiv, and Zaporizhzhia regions. Increased tariffs and the loss of duty-free access to the EU market make their products less competitive.

Logistics also remains a critical issue. Destroyed infrastructure, port blockades, and high transportation costs complicate access to third markets, even when demand exists in the EU.

Context from Brussels

According to Politico, the European Commission defended its decision to temporarily restrict duty-free access for Ukrainian agricultural products to the EU market, despite a wave of criticism from Ukraine and some European liberals. Meanwhile, Nazar Bobitski, Head of the UCAB EU office, called this a “step backward,” pointing out that Ukrainian exports make up only a small share of the EU’s agricultural market and do not threaten European farmers. The Commission insists that the new measures are a compromise between supporting Ukraine and protecting the farmers of EU member states, especially those in France, Poland, and Romania. However, critics argue that the Commission gave in to political pressure, and even within the European Parliament, voices are calling for the full restoration of liberalization. MEP Karin Karlsbro, rapporteur on Ukraine in the European Parliament’s Committee on International Trade, said the decision damages the EU’s image as a strategic partner of Ukraine.

What are the prospects?

Ukraine’s position is to activate Article 29 of the Association Agreement as soon as possible, which allows for a review of trade terms and the transition to a more stable and predictable regime. European partners, including sectoral associations in agriculture, have already expressed readiness for dialogue and acknowledged that the new restrictions could significantly affect Ukrainian producers.

According to Nazar Bobitskі, while the introduction of a transitional regime is not ideal, it does help avoid a full rollback. It creates conditions for further negotiations and allows Ukraine to maintain critical exports.

At the same time, experts urge the government and producer associations to step up advocacy for Ukrainian interests in Brussels and to seek new logistics and trade solutions.