The expiration of EU ATMs for Ukraine: What's next?
The EU autonomous trade measures (ATMs) for Ukraine expired in June 2025. Launched in mid-2022, the ATMs temporarily lifted the DCFTA exemptions from the duty-free regime, of which the TRQs on selected agro-food products were the most important. As a result, Ukraine’s exports to the EU of products subject to TRQs doubled to USD 4.7 bn.
As the ATMs expired, the trade regime will be defined by Article 29 of the Association Agreement and settled between the two extreme options. The most negative scenario for Ukraine is the reinstatement of the original DCFTA TRQs, causing USD 1.5 bn losses in exports to the EU. If the EU abolishes all TRQs, that will generate an additional USD 0.3 bn of Ukraine’s exports.
Ukraine’s exports to the EU subject to DCFTA-TRQs
The EU-Ukraine deep and comprehensive free trade area (DCFTA) envisaged duty-free access with some exemptions, the most important of which were the EU’s tariff rate quotas (TRQs) on selected Ukrainian agro-food products. In June 2022, the EU temporarily lifted these restrictions using ATMs.
As a result, Ukraine’s exports of goods subject to DCFTATRQs doubled to USD 4.7 bn, compared to USD 2.3 bn in 2021. The over-TRQ exports reached USD 4.0 bn. Moreover, a considerable export reorientation occurred, with the EU’s share in total exports of goods subject to DCFTA-TRQs increasing to 42% in 2024 from 18% in 2021.
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Under the ATMs, the number of product categories featuring over-TRQ exports to the EU increased from 11 in 2021 to 18 in 2024. The increase in maise, wheat, poultry, and sugar exports was particularly high.
What are the possible next steps?
With the ATMs expiring in June 2025, the question of the future trade regime arises. We considered four possible scenarios, with two extreme and two intermediate cases. As one extreme case, we considered returning the original DCFTA TRQs (S1), reintroducing duties on 85% of 2024 Ukraine’s exports subject to TRQs. That is the most harmful scenario for Ukraine. As another extreme, we model the permanent abolishment of DCFTA TRQs (S2). It is similar to the current status quo under the EU ATMs. Moreover, it is the regime that the country has when joining the EU. However, under S2, existing problems for some EU member states related to Ukrainian exports will not be resolved and may be exacerbated. That, in turn, could affect the current trade relations and the EU accession talks.
Therefore, S3 and S4 consider intermediate policy options, reinstating the original DCFTA TRQS for sensitive products and abolishing the TRQs for the rest of the goods. The main difference between S3 and S4 is in assumptions about the TRQ level for sensitive products. S3 envisages the return to the original DCFTA TRQs, while S4 sets the new TRQs at the level of 2024 exports.
These two scenarios are susceptible to the selection of sensitive products. We define sensitive products as those products fulfilling two out of the following three criteria:
- The level of EU out-of-quota duty,
- The ban on imports since 2023, and
- The emergency brake mechanism.
Based on this definition, we consider six products sensitive: wheat, sugar, poultry, honey, maise, and oats. When establishing the emergency brake mechanism, the EU defined the following products as “sensitive”: poultry, eggs, sugar, oats, maise, groats, and honey.
S1: Returning the original DCFTA-TRQs
S1 will hurt Ukraine the most. The Ukrainian exports to the EU, estimated based on EU data on traded quantities and Ukraine’s data on prices, would decrease by USD 1.5 bn compared to 2024, taken as a baseline. That equals 3.6% of total exports and 0.8% of GDP (2024). The impact of the original DCFTA-TRQs return on wheat exports would be the most profound, amounting to USD 0.9 bn. The other two products expected to experience high losses in EU exports are sugar (-USD 0.2 bn) and poultry (-USD 0.1 bn). Due to high import demand elasticity, trade in wheat, sugar, grape and apple juices, and barley could return to the volume within the TRQ limits.
S2: Full tariff liberalisation
S2 resembles the current situation (ATMs) regarding market access but adds longer-term predictability, lacking in ATMs. In the long term, the EU market’s openness will stimulate investments in additional production. However, for the short term, we assume that UKR’s exports of products subject to TRQs to the EU would remain within existing capacities, proxied as the maximum of the physical exports to the EU over the last three years. As a result, the immediate effect of full liberalisation will be moderate. Ukraine’s exports to the EU would increase by USD 0.3 bn, equivalent to ca. 0.7% of total exports and 0.2% of GDP. Based on their previous performance, producers of poultry and sugar would be the primary beneficiaries, with their exports growing.
S3: DCFTA-TRQs for sensitive products, no other TRQs
The S3 outcome is similar to S1, entailing significant losses for Ukraine’s exports to the EU. They would decrease by USD 1.2 bn, the loss equivalent to ca. 2.9% of exports and 0.7% of GDP (2024). The losses are mainly attributed to wheat exports, which would drop by USD 0.9 bn. As in S1, trade in wheat and sugar could return within DCFTA-TRQ limits. If our estimate follows the list of sensitive products defined for the EU emergency brake, where wheat, as the major driver, is not considered sensitive, the export loss to the EU will amount to ca. USD 0.3 bn.
S4: Higher TRQs for sensitive products, no other TRQs
S4, setting the new TRQs at the 2024 level, allows for retaining the status quo and preserving support for UKR. Still, it also establishes a cap on Ukrainian export expansion before full access is granted with membership. The Ukrainian exports to the EU would increase by USD 77 m.
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Implications and outlook
The ATMs’ expiration can be a considerable shock for Ukrainian exports to the EU. Depending on the scenario, export losses to the EU could reach up to USD 1.5 bn. Wheat, sugar, and poultry would be most affected if the original DCFTA-TRQs were reinstated.
However, the USD 1.5 bn export decline to the EU is not equivalent to Ukraine’s export revenue losses. Given the reinstating of the DCFTA-TRQs, Ukrainian producers are expected to reorient exports to non-EU markets. Therefore, the loss will be expected primarily in export price differences and shipping costs between EU and non-EU markets rather than in export volumes. So, the total export revenue losses will be much lower than USD 1.5 bn.
In 2021, the EU and Ukraine launched consultations about further tariff liberalisation under Article 29 of the Association Agreement. However, the full-scale Russian aggression and all subsequent events postponed the talks. The consultations have resumed, but all necessary procedures were not completed by 05 June, when the ATMs cease to exist. These talks will clarify which scenario Ukraine’s exports to the EU will follow.
Veronika Movchan is the Research Director of the Institute for Economic Research and Policy Consulting.
This newsletter is based on the Policy Study “The expiration of EU Autonomous Trade Measures for Ukraine: What’s next? Four scenarios and implications“.
