The European Union’s suspension of tariffs and quotas on Ukrainian agricultural exports — introduced in 2022 following Russia’s full-scale invasion — is set to expire on 5 June 2025. While the suspension, known as Autonomous Trade Measures (ATMs), has been extended multiple times, this time Brussels may reintroduce tariffs on certain products.

As Ukraine and the EU work toward a compromise version of “free trade” for agricultural goods, ASAP Agri’s Chief Grain Analyst Inna Stepanenko takes a closer look at how Ukrainian grain exports have evolved under the ATMs regime — and what might happen if tariffs and quotas return.

Looking back: Trade regime before ATMs

Before the full liberalization of trade under ATMs, the EU applied tariff-rate quotas (TRQs) to Ukrainian grain exports. In 2021, the annual duty-free quotas were as follows:

  • Wheat – 1 MMT
  • Corn – 650 KMT
  • Barley – 350 KMT

Any exports exceeding these quotas were subject to Most Favored Nation (MFN) tariffs:

  • Common wheat – 95 EUR/MT
  • Barley – 93 EUR/MT
  • Corn – 94 EUR/MT

However, for corn, the EU’s variable tariff system often resulted in zero or minimal duties due to high global market prices at the time.

Surge in Ukrainian grain exports to the EU

The full liberalization of trade with the EU significantly boosted Ukraine’s grain exports to the bloc.

In the 2020/21 MY, the EU accounted for just 4% of Ukraine’s wheat exports (about 0.7 MMT). By 2023/24, that share had skyrocketed to 46% (8.5 MMT).

Spain emerged as the dominant EU destination for Ukrainian wheat, becoming the top importer globally in 2023/24. Although Ukrainian wheat exports to the EU declined in the 2024/25 season, Spain remains the leading market, with Italy also showing a notable increase in demand.

Corn was already a key export to the EU before the ATMs regime. In 2020/21, the EU imported 7.4 MMT, making up 31% of Ukraine’s corn exports. However, the opening of the EU market allowed Ukraine to expand its footprint, and by 2023/24, the bloc’s share had risen to 50% (14.6 MMT).

Again, Spain led the pack — not only as the largest EU buyer but also as Ukraine’s top corn destination globally. Significant increases were also seen in exports to Italy, with the Netherlands remaining a key importer.

The barley segment followed a similar trajectory. In 2020/21, the EU accounted for just 2% (0.1 MMT) of Ukrainian barley exports. By 2023/24, that share had surged to 42% (1.1 MMT).

Here too, Spain solidified its position — rising from zero imports in 2020/21 to nearly 0.5 MMT in the 2024/25 MY, making it the second-largest global buyer after China. Cyprus also recorded a notable increase in Ukrainian barley imports.

Grain diplomacy in motion: wheat quotas on the table, corn exempt — for now

While negotiations between Ukraine and the EU are ongoing, the outlook for Ukrainian corn exports to the bloc remains relatively positive, according to sources familiar with the matter.

In contrast, the wheat export situation appears more complex. Current discussions in Brussels include the possible reintroduction of a 1 MMT annual import quota for Ukrainian wheat. Volumes exceeding this threshold could, under certain scenarios, face a 95 EUR/MT tariff. Although no final decision has been made, such a move — if implemented — could have a significant impact on Ukraine’s wheat exports to the EU, which accounted for 35% of total wheat exports between July and April of the 2024/25 season.

Commenting on the possible implications for the Spanish feed industry — the largest consumer of feed wheat in the EU —  Jorge de Saja, General Director of the Spanish Feed Industry Federation, noted:

“We are not pleased to see any event that might affect the price or availability of raw materials we import to serve our needs. At present, we are working with our authorities — on one side, to keep a reasonable price for corn imports from the U.S. amid the ongoing tariff discussions, and on the other, to reopen the EU market to Argentinian corn. These are times of change that could reshape commodity flows and markets for years to come. Let us hope the changes, in the end, are for the better.”

His comments reflect broader concerns among European importers over the potential disruption of established supply chains — including for feed wheat — and the growing need for diversified, stable, and competitively priced sources.

ASAP Agri will continue to follow the situation closely and provide timely updates in the Premium Reports.

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