Honey Quota Rises from 6,000 to 35,000 Tonnes: The EU’s New Tariffs for Ukraine

On October 29, 2025, a new tariff arrangement was added to EU-Ukraine trade. The volume of Ukrainian honey that can enter the EU duty-free expanded from 6,000 to 35,000 tonnes a year, and white sugar from 20,070 to 100,000 tonnes. At the same time, this is not a return to the “no tariffs, no quantity quotas” situation that continued for three years after Russia’s full-scale invasion.

This article traces the course from the tariff exemption of June 2022, through its end in June 2025, to the revision of the agreement in October, based on the text of EU regulations and decisions and explanatory materials from the European Commission. Figures and circumstances are as of September 2026. The EU accession negotiations themselves are covered in our article on how far Ukraine’s negotiations have advanced, four and a half years after applying for EU membership, and grain export routes in our article on where Ukraine’s grain is shipped from, the summer the port of Odesa was halted by attacks.

The Original Agreement: Duty-Free for Most Goods, Quotas for 40 Product Groups

The EU-Ukraine Association Agreement includes a chapter on the Deep and Comprehensive Free Trade Area (DCFTA), which applied provisionally from January 1, 2016, and entered into force on September 1, 2017. According to the European Commission’s explanation, under this agreement the EU eliminated tariffs on all goods except those covered by 40 tariff-rate quotas (TRQs). A tariff-rate quota is a mechanism under which goods can be imported duty-free or at a reduced rate up to a set quantity, beyond which the normal tariff applies.

Article 29 of the agreement provides that, five years after entry into force, either party may request consultations to accelerate or extend tariff elimination. At Ukraine’s request, consultations began in 2021, but were suspended after the full-scale invasion (per the preamble to the 2025 Committee decision).

June 4, 2022: Tariffs and Quotas Suspended

By Regulation (EU) 2022/870 of May 30, 2022, the EU established “Autonomous Trade Measures” (ATM) for Ukrainian products. These were temporary preferences granted unilaterally by the EU, applied from June 4, 2022. The regulation’s preamble gives the reason as “Russia’s unprovoked and unjustified war of aggression against Ukraine since 24 February 2022,” which had destroyed Ukraine’s production capacity and closed off its access to the Black Sea.

The main provisions of the regulation were as follows.

• Eliminate all remaining import tariffs on industrial products
• Suspend the application of the “entry price system” for fruits and vegetables
• Suspend tariff-rate quotas and eliminate tariffs on the agricultural products that had been subject to them
• Not impose anti-dumping duties on imports made during the period of application
• Suspend the application of the EU’s import safeguard regulation (2015/478)

The measures were extended annually: by Regulation (EU) 2023/1077 of May 31, 2023, from June 6, 2023 to June 5, 2024, and by Regulation (EU) 2024/1392 of May 14, 2024, from June 6, 2024 to June 5, 2025.

Pushback from Neighboring Countries, and EU Import Restrictions

According to the preamble of the Commission’s regulation, congestion and high costs in the logistics for moving Ukrainian grain further into the EU or outside it led to increased imports into the member states neighboring Ukraine. By Implementing Regulation (EU) 2023/903 of May 2, 2023, the Commission adopted “preventive measures” barring Ukrainian wheat, maize, rapeseed and sunflower seeds from being released for free circulation (placed on the domestic market) in five countries — Bulgaria, Hungary, Poland, Romania and Slovakia. The preamble explains that storage and logistics in these countries had become saturated, affecting the businesses of local producers. Transit was not blocked.

After applying through June 5, this measure was extended to September 15, 2023 by an Implementing Regulation (EU) 2023/1100 with the same content. According to WTO (World Trade Organization) records, on September 18, 2023, Ukraine requested WTO consultations regarding the measures that Poland, Hungary and Slovakia had each imposed on imports of Ukrainian agricultural products (dispute numbers DS619–DS621).

An “Emergency Brake” Added to the 2024 Extension

Regulation (EU) 2024/1392 of 2024 added a safeguard along with the extension. For seven products — eggs, poultry meat, sugar, oats, maize, groats (crushed cereal grains) and honey — if that year’s import volume reached the average of imports from July–December 2021, 2022 and 2023, the European Commission was required to restore the tariff-rate quota for that product within 14 days (Article 4(7)).

According to the European Commission’s explanation, this brake was triggered for five products.

Poultry meat and maize are not among the products the European Commission lists as having triggered the brake.

Ending on June 5, 2025, and a Return to the Original Quotas the Next Day

The third round of measures was not extended and ended on June 5, 2025. According to the European Commission’s explanatory document (July 2025), from June 6 the Association Agreement’s original tariff-rate quotas reopened, serving as a transitional arrangement until the agreement’s revision was implemented.

The course of the revision was as follows.

The decision set the 2025 quota amount at 7/12 of the new annual quota (Article 2), since the switch to the new quotas took place partway through the year.

The New Quotas: Products Increased, Products Left Unchanged

The European Commission’s explanatory document states that, in the revision, cereals such as wheat and maize, along with sugar, honey, poultry meat and eggs, were treated as “products sensitive for EU agriculture” and given only limited increases, while no additional volume was granted for other meats. The main products are as follows.

Conversely, some products had their quotas removed entirely and became duty-free. The explanatory document cites fermented milk, processed cream, mushrooms, food preparations, grape juice, whole milk powder, and yogurt and kefir, among others.

The Condition: Aligning with EU Production Standards by 2028

The new quotas come with a condition. Annex I-E, added to the agreement by the decision, requires Ukraine to align its laws with the EU legislation listed in Appendix C by December 31, 2028. Appendix C lists regulations and directives covering animal welfare in the raising, transport and slaughter of livestock, the sale and use of pesticides, veterinary medicines, feed, and genetically modified crops, among others.

Ukraine will report on its progress each year and submit a final report by the end of 2028. If the European Commission is unable to determine that alignment has been achieved, the EU may, after consultations, suspend all or part of the preferences for the relevant products (Annex I-E, Article 2).

The other is a safeguard (emergency import restriction). If increased imports resulting from the additional tariff cuts cause, or threaten to cause, serious difficulties for either side, that side may, after notification and consultations, take appropriate measures. On the EU side, this includes difficulties arising in one or more member states (Annex I-E, Article 3). The decision further provides that in 2028 the two sides will jointly assess whether to proceed further with tariff elimination, taking into account the progress of Ukraine’s accession negotiations (Article 3).

Ukraine’s Side Also Expanded Its Quotas

The revision runs both ways. Ukraine maintains tariff-rate quotas on three EU products, and according to the European Commission’s explanatory document, these increased as follows: pork from 20,000 to 45,000 tonnes, poultry meat from 20,000 to 120,000 tonnes, and sugar from 40,000 to 100,000 tonnes. Ukraine will also lower or eliminate tariffs on EU dairy products, feed, fish and other goods.

The three years of “no tariffs, no quotas” that the EU opened immediately after the full-scale invasion were a temporary measure to support Ukraine’s economy. The framework in place from October 2025, as part of an agreement with no expiration date, combines quantity ceilings, movement toward EU standards, and an emergency safeguard.