How to Adjust Contracts and Logistics to Capture the 7/12 Share of Tariff-Rate Quotas and Avoid the “Emergency Brake”.

On 6 June 2025, the EU’s three-year Autonomous Trade Measures (ATM) period ended. The duty-free “trade visa-free” regime was replaced by transitional tariff-rate quotas (TRQs) equal to 7/12 of annual limits, in force until 31 December 2025, plus an “emergency brake” mechanism for sensitive products (sugar, poultry, eggs). In parallel, Brussels and Kyiv opened talks on an “enhanced DCFTA 2.0” with sustainability and digital components. The absence of a new agreement could cost Ukrainian exporters up to €3.5 billion per year, so rapid adaptation to quotas, certification, and FX risk is critical.

Geopolitical and economic context
After the ATM was introduced in June 2022, Ukraine regained access to the EU’s internal market: the EU’s share in Ukraine’s goods turnover reached 50%, and total trade exceeded €67 billion in 2024.

The extension of liberalisation through 2025 was accompanied by discontent among European farmers, who complained about price pressure from cheaper Ukrainian grain and sugar. In response, the EU introduced an “emergency brake” in 2024 for sugar, eggs, and poultry: if average 2022–2023 import volumes are exceeded, duties are reinstated.

The decision not to prolong the ATM after 5 June 2025 was driven by several factors:
• A political signal to support the farming electorate ahead of elections in a number of Member States.
• A scheduled review of temporary measures built into the Regulation itself.
• A shift to negotiations on systemic integration under a DCFTA 2.0 format.

Alongside the end of the ATM, the EU confirmed the “solidarity lanes” and allowed permit-free freight transit until end-2025, preserving logistical flexibility for Ukrainian exporters.

New trade rules: quotas and the “emergency brake”
Product — Annual TRQ before 2022 — Available volume from 6 June to 31 December 2025 (7/12)
• Wheat — pre-2022 annual quota: 1 million tonnes. Available 6 June–31 December 2025: 583,000 tonnes (i.e., 7/12 of the annual quota). Allocation is on a first-come, first-served basis.
• Barley — initial quota: 350,000 tonnes; during the 2025 transition period exporters can use 204,000 tonnes. Allocation rules mirror wheat.
• Maize — annual TRQ: 650,000 tonnes; currently available: 379,000 tonnes. The tariff remains at zero, so no significant price impact is expected.
• Raw sugar* — pre-war quota: 20,000 tonnes; the transitional volume until end-2025 is only 11,700 tonnes. Until 2024, over 500,000 tonnes per year were supplied to the EU market, therefore the “emergency brake” applies to sugar.
• Poultry and eggs — instead of a fixed TRQ, a licensing scheme applies. In 2025 the limits are reduced proportionally, and the “trigger threshold” is set at the average imports of 2022–2023.

*Note: after 1 January 2026, quotas will automatically revert to full annual volumes unless the parties conclude DCFTA 2.0.

How the “emergency brake” works
• Monthly import monitoring by EU statistical services.
• Automatic collection of evidence on exceeding baseline-year averages.
• A European Commission decision to reinstate duties is taken within 14 days and applies until year-end.

For Ukrainian exporters, this means:
• Shipment scheduling: concentrate dispatches in the first half of each quarter, when quotas are less likely to be exhausted.
• Reallocate part of volumes to alternative markets (MENA, Southeast Asia).
• Optimise contractual Incoterms with customs-duty risk in mind.

The outlook for DCFTA 2.0 and the “industrial visa-free regime” (ACAA)
On 4 June 2025, the European Commission and the Government of Ukraine opened talks on an updated agricultural chapter of the DCFTA. According to Agriculture Commissioner Christoph Hansen, future quotas will be “between” the pre-war limits and ATM volumes; in particular, the sugar quota will be “significantly higher” than the previous 20,000 tonnes.

The new package will include:
• Climate and digital chapters integrating carbon-footprint requirements and electronic veterinary certificates.
• A dedicated safeguard protocol that standardises customs-response algorithms for all sensitive lines.
• Pilot ACAA integration in three clusters: mechanical engineering, low-voltage equipment, and medical devices. The agreed plan provides for full conformity assessment by end-2025, after which Ukrainian manufacturers will gain EU market access without repeat certification.

In the consolidated Priority Action Plan 2025–2026, the European Commission has already earmarked early integration of Ukraine into the Single Euro Payments Area and Roam-Like-at-Home, confirming the strategic course toward economic convergence.

Practical implications and Alstera recommendations

Strategic quota booking
• Register wheat and barley contracts by 15 July, while >60% of the quota remains available.
• Use combined routes (river + rail) to accelerate border crossings.

Market diversification
• Step up sales in Morocco, Egypt, and Indonesia, where grain prices remain attractive.
• For sugar, focus on the Balkans and the Middle East to minimise the risk of triggering the “emergency brake”.

Invest in value-added processing
• The Ministry of Agrarian Policy has already announced subsidy programmes for oilseed processing. Launching a bottled-oil or protein-concentrate line lifts margins and falls outside the quotas.

Financial hedging
• Enter EUR/UAH options with maturities up to nine months to smooth profitability amid possible volatility during the Brussels talks.
• Use export-contract insurance (ECA) with political-risk cover.

Prepare for ACAA
• Implement ISO 9001 and EN IEC 60204-1 in equipment manufacturing.
• Run internal audits against the EU Construction Products Regulation to shorten time-to-market once the agreement is signed.

This article was prepared in part using materials from policy.trade.ec.europa.eu and reuters.com.