Effective 6 June 2025, the European Union will terminate the temporary autonomous trade liberalisation measures for Ukraine, which were introduced in 2022 in response to russia’s full-scale invasion. From now on, the regulatory framework will revert to the provisions of the EU-Ukraine Association Agreement — specifically, the rules on tariff quotas for agricultural products.
What has changed as of now?
On 5 June, the European Commission published Regulation 1132/2025 (https://lnkd.in/enXX8AnA), which sets out the new rules governing tariff quotas for imports of Ukrainian agricultural goods. The Regulation enters into force on 6 June 2025.
Annual quota volumes remain unchanged:
• 350,000 tons of barley
• 650,000 tons of maize
• 1,000,000 tons of wheat
However, due to the Regulation’s mid-year entry into force, quotas for 2025 will be allocated on a pro rata basis — specifically, 7/12 of the annual volumes, covering the period from 6 June through 31 December 2025.
Key change: “First come, first served” principle
Unlike previous mechanisms, quota allocations will now follow a strict chronological order of application submission. This means that timely execution and strategic planning of import-export operations will become critical for agribusiness operators.
In cases where quotas are exhausted, importers will be required to pay the standard duties applicable to all third countries (erga omnes). For example, the standard duty for wheat is €12 per ton. Once these volumes are also exceeded, out-of-quota tariffs will apply — significantly higher, such as €95 per ton for wheat.
The restoration of the tariff regime is not a step backwards, but a signal for Ukrainian businesses to integrate into the European market on a long-term basis. The new rules are a challenge but also an opportunity to adapt and professionalize export strategies.
Analytical review by Olga Kostyshyna, Counsel, Head of International Arbitration, and Katerina Lihopeka, Junior Associate, LCF Law Group