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Federation of Employers of Ukraine

FEU

- representing the rights and interests of employers in the economic, social, labour and other fields in relation to national executive authorities, local governments, trade unions, civil society associations, institutions, and organizations; - representing interests of its members in cooperation with international organizations, authorities, employer organizations, business associations, and companies of foreign countries; - promoting economic development, preserving the existing and creating new jobs; - supporting sustainable development of industrial production; - supporting the integration of the Ukrainian business to the EU Single market; - promoting exports of the member companies to foreign markets with a focus on the EU market; - facilitating the implementation of European environmental policies in the national industry with regard to national context; - promoting interests of the members in thr of implementation of the Association Agreement

Lobbying Activity

Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

22 Aug 2025

The Federation of Employers of Ukraine would kindly ask the European Commission to consider applying the provisions of Article 30 (7) of Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon border adjustment mechanism (hereinafter referred to as the Regulation) to Ukrainian manufacturers of goods subject to the Regulation. According to the above provision: "Where an unforeseeable, exceptional and unprovoked event has occurred that is outside the control of one or more third countries subject to the CBAM, and that event has destructive consequences on the economic and industrial infrastructure of such country or countries concerned, the Commission shall assess the situation and submit to the European Parliament and to the Council a report, accompanied, where appropriate, by a legislative proposal, to amend this Regulation by setting out the necessary provisional measures to address those exceptional circumstances". In connection with the ongoing large-scale armed aggression of the Russian Federation against Ukraine, Ukraine meets all three criteria set out in Article 30(7) of the Regulation: 1. An unforeseen, exceptional and unprovoked event occurred - a full-scale invasion of Ukraine by the Russian Federation, unprovoked by our state; 2. This event is beyond the control of one or more third countries to which the CBAM applies - Ukraine independently defends its independence: a full-scale war has been going on for more than three years, and Russian armed aggression has been going on for more than 10 years since 2014. 3. This event has devastating consequences for the economic and industrial infrastructure of such a country or countries - direct losses alone as of November 2024 are estimated at 170 billion USD. During the war, it is extremely difficult to implement effective measures aimed at decarbonization, as well as to attract investment for this or receive assistance from the state. At the end of 2024, the Federation of Employers of Ukraine completed economic modeling of the impact of CBAM on the economy of Ukraine. Apparently, these consequences will be extremely critical for our state, which is in a full-scale war and budget funds (funds from taxes and fees paid by businesses) are spent, primarily, on ensuring defense capabilities. In a nutshell, already in the first year of full-scale CBAM application (2026), Ukraines GDP will decrease by 4.8%, exports of goods to the EU - by 7.8 %, the index of manufacturing industry products - by 13.1 %. Tax revenues will decrease by 2.8 billion USD, and about 73.1 thousand jobs will be lost as a result of reduced business activity. As the price of carbon emissions (and therefore the price of purchasing CBAM certificates) is set to increase in the EU, the above-mentioned negative effects will deepen and in 2030 and the mid-30s will reach, respectively, a 6.1 % and 6.3 % drop in GDP, a 9.8 % and 10.1 % reduction in merchandise exports to the EU, a 16.7 % and 17.1 % drop in the processing industry, a decrease in tax revenues of 3.5 and 3.6 billion USD, as well as the loss of almost 120 thousand jobs. More details of the research can be found here - https://fru.ua/images/doc/2025/Research_impact_assessment_EN.pdf The Government of Ukraine has shared with the Federation, that earlier this year it had addressed the European Commission with a request regarding the application of the provisions of Article 30 (7) of the Regulation. In the light of this, we would kindly ask the European Commission to consider applying the provisions of Article 30 (7) of the Regulation towards Ukraine in the course of review/ introducing amendment to the Regulation scheduled further in 2025.
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Meeting with Gert Jan Koopman (Director-General Enlargement and Eastern Neighbourhood)

27 Mar 2025 · Presentation of the research done by the FEU and discussion on economic cooperation between the EU and Ukraine

Meeting with Outi Slotboom (Director Internal Market, Industry, Entrepreneurship and SMEs) and

27 Mar 2025 · Exchange of views on opportunities for deepening trade and economic relations between the European Union and Ukraine

Meeting with Pierre Bascou (Deputy Director-General Agriculture and Rural Development) and

25 Mar 2025 · FEU study: ‘Strategic guidelines for deepening trade and economic relations between Ukraine and European Union countries’ Review of the EU-Ukraine Deep and Comprehensive Free Trade Area (DCFTA)

Meeting with Nicolas Schmit (Commissioner)

10 Oct 2024 · The importance of social dialogue, capacity building and consultation of social partners on labour reforms

Response to Further reciprocal tariff liberalisation under Art. 29 of the EU-Ukraine Association Agreement

30 Sept 2024

The removal of tariff barriers has proven effective, and its continuation would further facilitate Ukraines gradual integration into the EU Single Market. However, the increased trade volumes have revealed certain challenges both at the member states and at the EU level. The rise in Ukrainian imports of certain products, such as eggs, poultry, sugar, oats, corn, cereals, and honey, has prompted concerns within the EU agricultural sector, leading to the implementation of restrictions outlined in Regulation No. 2024/1392 of 14 May 2023. While the intention behind these measures was to balance trade opportunities for Ukraine with the protection of the EU internal market, the FEU believes that restricting Ukrainian exports has had unintended negative consequences, particularly on price stability and the availability of certain goods in the EU market. Ukrainian agricultural products have become essential in stabilizing prices and ensuring food security within the EU, providing European consumers with savings amounting to hundreds of millions of euros annually. Therefore, removing trade barriers under Article 29 of the Association Agreement will support both Ukrainian and EU businesses, ensuring economic resilience and further integration, and of course, will benefit European consumers. We propose that the revision of the Agreement should focus on the following key areas: 1. Full tariff liberalization, eliminating quotas where trade volumes have historically been negligible. 2. Abolishing the EU entry price mechanism. 3. Establishing quotas based on 2023 import volumes, with a 10-20% annual growth over the next 5-7 years. 4. Segmenting quotas for specific goods, such as flour, juices, and other commodity items. 5. Developing market access plans for animal products that are currently excluded. 6. Removing the poultry meat quota. The temporary trade liberalization under the Association Agreement not only eliminated tariffs but also suspended anti-dumping duties and protective measures (EU steel safeguards) on Ukrainian metallurgical products like seamless pipes and metal products. It's important to highlight that while protective measures (EU steel Safeguards) still exist, they are currently not applied to metal products from Ukraine. During the period of trade liberalization, the suspension of duties and protective measures did not result in any negative impact on the EU internal market. Ukrainian metallurgy, whose key facilities are predominantly located in the eastern and southern regions, has been particularly affected by the ongoing Russian aggression. Extending these measures will be vital for supporting Ukrainian industry, particularly the metallurgical sector, which has been severely affected by the war. The best way to achieve this goal is to amend CHAPTER 2 Trade remedies of TITLE IV TRADE AND TRADE-RELATED MATTERS of the Association Agreement by laying it down in the following wording: No Party shall apply any anti-dumping, countervailing or global safeguard measures in bilateral trade. Therefore, in order to accelerate the integration of Ukrainian producers into the EU Single Market and support the sectors of the Ukrainian industry that suffered the greatest losses as a result of the war, we propose to amend the Association Agreement, which would extend the regime of cancellation of any trade protection measures both by the EU and by Ukraine such, for example, as an anti-dumping duty. If no agreement is reached under Article 29 of the Association Agreement by April 2025 we propose that the current Autonomous Trade Measures remain in effect until a new agreement is finalized and the corresponding decision by the EU-Ukraine Association Committee in its trade configuration is implemented.
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Meeting with Valdis Dombrovskis (Executive Vice-President) and European Business Association

8 Mar 2024 · EU-Ukraine trade relations, Ukraine Facility – possibilities for business.

Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

16 Nov 2023 · The integration of the agricultural sector of Ukraine to the EU, in particular gradual accession of the Ukrainian agro-industrial complex to the EU trade market, future changes of the Common Agricultural Policy with regard to the start of pre-access