Ukraine’s 2026 soybean supplies to EU in question: exporters avoid forward contracts over EUDR risks — ASAP Agri
Just as the Ukrainian market began to recover from the newly introduced 10% export duty on soybeans, another wave of uncertainty emerged. Farmers, processors, and traders once again find themselves in limbo: no one can say with confidence whether the EU will start applying the Regulation on deforestation-free supply chains (EUDR) exactly on 30 December 2025, or whether its implementation will be postponed yet again.
For the market, this ambiguity has a direct and critical consequence: most major Ukrainian exporters are avoiding contracts for soybean complex products with delivery dates from 1 January 2026 onward, choosing caution over potentially costly regulatory risks, says Victoria Blazhko, Head of Editorial, Content and Analytics at ASAP Agri.
Despite active debates within the EU and calls from several member states to delay the launch of EUDR by at least a year, the European Commission made its position clear in mid-October: no postponement is planned. Instead of the full one-year delay discussed earlier, Brussels proposed a six-month “transition period” for inspections and enforcement, along with a simplified compliance regime for small operators. In practical terms, the launch date remains unchanged — only the mechanics of entering the system are being softened.
The regulation maintains its original objective: reducing the EU’s contribution to global deforestation by ensuring full transparency and traceability of key commodities such as soybeans, cocoa, coffee, palm oil, timber, and beef. Large and medium-sized companies will still be required to comply with EUDR from 30 December 2025, while full enforcement will begin on 30 June 2026. Micro and small operators have until 30 December 2026. The European Parliament and Council are expected to adopt the final technical amendments by the end of the year.
Even with these adjustments, Ukrainian exporters are approaching the timeline with caution. The main concern lies in the gap between the start of compliance obligations (30 December 2025) and the beginning of enforcement and penalties (30 June 2026). This interim period is often misunderstood as a “grace window.” In reality, the opposite is true: any product entering the EU market after 30 December 2025 must already be EUDR-compliant — and once enforcement begins, these shipments may be inspected and sanctioned retroactively. With such risks in play, many traders prefer to wait rather than face a scenario where the goods are shipped but fail an EUDR check months later.
Victoria Blazhko
Head of Editorial, Content and Analytics at ASAP Agri
"For Ukraine, the implications are significant. The EU is a critical market for soybeans and their products. Last season, the EU accounted for 43% of soybean exports, 87% of soybean oil, and 82% of soybean meal. Although the EU share temporarily eased in the first two months of the 2025/26 season, its long-term importance remains unquestionable."
Since the bulk of Ukraine’s soybean exports typically falls in the second half of the marketing year — precisely when EUDR will apply in full — ASAP Agri’s estimates point to a substantial at-risk segment. Potentially exposed volumes include around 500 KMT of soybeans, 350 KMT of soybean oil, and 750 KMT of soybean meal. These figures reflect the volumes Ukraine may ship to the EU based on historical market shares.
More: If we add even a small EUDR premium to Ukrainian soybean meal now, we won’t sell a single ton — analysts
It is important to note that not all export volumes are vulnerable: some Ukrainian producers and crushers already have the necessary documentation and can ensure full EUDR compliance. Still, sector readiness is uneven. Large agricultural holdings and advanced processors are actively mapping fields, geolocating plots, establishing traceability chains, and preparing due-diligence files — some even testing their systems on upcoming contracts. In contrast, medium and small operators progress much more slowly: documentation is incomplete, land-use histories are not always formalized, and many farms lack digital tools for record-keeping. The ongoing war, limited access to cadastral systems, and periodic registry outages only deepen the challenge.
Ukraine has the capacity — both technological and legal — to adapt. But time is limited, and the stakes are high. The EU remains far too important a market to risk losing even partially. The outcome will depend on two critical factors: Brussels’ final decision on the EUDR and how quickly Ukraine can build a reliable traceability system “from field to border.”
