Oleksandr Chupak Head of Economic Programs at the Non-Governmental Analytical Centre "Ukrainian Studies of Strategic Disquisitions"

Deep and Comprehensive Free Trade Act effectively makes Ukraine ‘unofficial’ EU member

World
17 November 2025, 14:25

Replacing the temporary ‘trade visa-free regime,’ Ukraine and the European Union have struck a new long-term deal. Here’s a closer look at what it entails, the benefits for both sides, and the challenges that could lie ahead.

Lack of political will

Let’s be frank: Ukraine’s path to EU membership hinges almost entirely on the political will of Brussels and the bloc’s member states. If the EU decides it wants Ukraine in, accession could happen quickly, and hurdles like corruption or regulatory gaps would likely be brushed aside.

For Ukraine, though, joining the EU shouldn’t be treated as the end goal. The Union itself is constantly evolving, shaped by internal shifts — changes in governments across key member states — and external pressures from the United States, China, and Russia. As recent history shows, even enshrining the ambition to join the EU and NATO in Ukraine’s Constitution did little to secure electoral success for the previous government — let alone actual membership in either organisation.

Amid the full-scale war with Russia, Ukraine has been slowly edging closer to what could be described an ‘unofficial’ EU membership. And it’s not just about the billions in financial aid: by 31 August 2025, the EU had already sent €177 billion, with another €96.2 billion on the way. But the real story lies in Ukraine’s gradual integration into the EU’s common market—a journey that began with the 2014 Association Agreement, a deal forever marked by the blood of the Heavenly Hundred.

On 29 October 2025, Ukraine took another big step forward: the Deep and Comprehensive Free Trade Area (DCFTA) Agreement officially came into force. This isn’t just a technical milestone. It marks a closer economic connection with Europe, opening the door to a more integrated market while showing the hurdles that still lie ahead, especially those from some of our western neighbours.

Keeping Orbán in check

From June 2022 to June 2025, Ukraine and the EU operated under a set of autonomous trade measures, widely known as the ‘trade visa-free regime’. These measures were designed as a lifeline for the Ukrainian economy, coming at a time when important sea routes were blocked by the Russians, major industrial centres like Mariupol were under occupation, and Ukraine was facing a dramatic loss of economic capacity—Ukraine’s GDP plunged by 29% in 2022. Between June and October 2025, transitional measures were put in place for Ukrainian exports to the EU, keeping the free trade regime alive until the long-term agreement could be signed.

By the end of 2024, the EU had established itself as Ukraine’s largest trading partner, accounting for more than half of our goods exports—up from 39% in 2021. On the other hand, Ukraine is still only the EU’s 16th-largest partner, accounting for a modest 1.3% of its trade. Still, total trade between the two parties reached a staggering €67.2 billion last year.

The biggest gains under the ‘trade visa-free regime’ came in agriculture, where exports skyrocketed by 117%. Even with resistance from countries like Poland and Hungary, Ukraine surged to become the EU’s third-largest supplier of agricultural products, trailing only behind Brazil and the United Kingdom.

The updated Agreement is built on three key principles that will shape how Ukraine trades with the EU going forward.

First, equal rules for everyone mean that Ukraine’s access to the European market is tied to a gradual alignment with EU standards on everything from pesticides to veterinary products. The country will report annually on its progress, providing a clear path toward deeper integration. Second, the Agreement includes a protective mechanism, allowing both sides to step in if imports threaten to cause serious harm. Within the EU, potential violations can be assessed by one or several member states—a safeguard that helped win over sceptics and secure approval. Finally, the deal aims to expand trade flows while balancing the protection of domestic interests, particularly in agriculture. Access to the market varies depending on how sensitive a product is: for sugar, poultry, eggs, wheat, corn, and honey, only a moderate increase is allowed compared with previous conditions, while less sensitive products are fully liberalised.

In simple terms, the new Agreement still imposes some limits on Ukraine compared with the old ‘trade visa-free regime.’ But it represents a major step forward from the pre-war market setup, giving Ukrainians broader access to the European market—and giving EU consumers more access to Ukrainian goods in return.

Ukrainian wheat shapes European vote

There’s no getting around it: implementing the Agreement won’t be smooth sailing. A major stumbling block comes from Poland, Slovakia, and Hungary, which imposed national-level embargoes on Ukrainian agricultural products back in September 2023. Ukraine can sell its goods at far lower prices, and with market barriers removed under the ‘trade visa-free regime,’ local producers in these countries started losing out to imports. The backlash has been fierce—so much so that it became a real electoral issue, and farmers’ protests at border crossings are still ongoing.

With the Agreement now in place and its protective mechanisms included, Brussels is pushing for the embargoes to be lifted, arguing that they violate the EU’s internal market rules. Politico reports that the European Commission is even weighing the possibility of legal action against the dissenting countries, despite accusations that the bloc is tilting in Ukraine’s favour over its own member states.

Another major hurdle is the sheer size of Ukraine’s agricultural land—42 million hectares, putting it far ahead of second-place France, which has 28.8 million hectares.

Under the EU’s Common Agricultural Policy, funding is distributed based on the amount of arable land, which would put Ukraine at the top of the list. At the same time, Ukrainian farmers aren’t weighed down by the heavy standardisation that drives up costs for their European counterparts.

Still, as EU Trade Commissioner Maroš Šefčovič points out, the Agreement “represents the best possible outcome under difficult geopolitical circumstances.” The arrival of a new player on the market always stirs competition—and sometimes brings losses for established participants. But in the bigger picture, Ukraine’s long-term integration is expected to be a net win for the EU.

Cashing in on the opportunity

The European Union may be coming out ahead, but what about Ukraine? For us, the chance to trade freely with Europe isn’t just an economic perk—it’s a lifeline keeping the economy from sliding into the abyss. The numbers speak for themselves: since finally breaking up with Russia, the EU market has become absolutely central to Ukraine’s economic survival.

One of the biggest wins in the new Agreement? Its long-term nature. Gone are the days of constantly worrying about when the ‘trade visa-free regime’ would end. Ukrainian entrepreneurs can now plan ahead, confident they won’t have to pull back operations every time the rules change. And where there’s certainty, investment follows.

Even if Brussels, Berlin, or Budapest remain hesitant to fully welcome Ukraine into the EU, and even as critics continue to flag the war, corruption, or other shortcomings, Ukraine has already carved out a role as the EU’s ‘unofficial’ member through the Deep and Comprehensive Free Trade Area. The next step is clear: make the most of this special status and turn it into real gains for the country.

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