Ukraine’s free trade agreement with Turkey removes the regular 10% import duty on fresh cucumbers and tomatoes, but does not affect the anti-dumping duties currently applied to Turkish supplies. According to Angela Makhinova, a leading Ukrainian international trade lawyer and partner at Sayenko Kharenko, the existing measures will remain in force after the agreement takes effect.
Ukraine introduced anti-dumping duties of 20.1–26.9% on fresh cucumbers and tomatoes from Turkey in July 2025 for five years. The investigation found that Turkish suppliers had sold the products at dumped prices, while Ukrainian producers had lost sales, reduced production, and operated at negative profitability.
The measures did not stop Turkish imports, but increased their cost and partly improved competitive conditions for Ukrainian greenhouse growers. In the first quarter of 2026, Turkish cucumbers entered Ukraine at an average of €1,100 per tonne, compared with €1,500 for the EU market and €2,200 for Germany. Turkish tomatoes were imported at around €1,000 per tonne, about half the price for supplies to Romania.
Under the FTA, the regular 10% duty is eliminated, but importers will continue to pay the anti-dumping duties and VAT. The removal of the regular tariff could allow Turkish suppliers to lower their prices in Ukraine and increase pressure on local greenhouse producers.
The FTA does not provide automatic grounds for reviewing, suspending or cancelling the anti-dumping measures. Ukrainian legislation and WTO rules allow an interim review one year after the duties were introduced. Foreign producers and exporters can request such a review, which may result in the duties being reduced, maintained, increased or cancelled. The measures can also be suspended for nine to 12 months under specific conditions.
A bilateral safeguard mechanism is available if imports increase sharply and cause or threaten serious injury to Ukrainian producers. However, such a measure would effectively restore the regular tariff, which for cucumbers and tomatoes is 10%. This is lower than the current anti-dumping rates.
The legislation and the FTA do not set a single import-growth threshold for triggering such a mechanism. Ukrainian producers therefore need to monitor imports and market conditions and use the available trade-defence procedures where the relevant conditions are met.
The potential impact extends beyond greenhouse vegetables. In 2025, Ukraine imported $81.7 million worth of fresh tomatoes, $33.3 million of cucumbers, $23.7 million of other fresh vegetables and $30.7 million of grapes from Turkey.
Market access under the agreement is not fully symmetrical. Turkey provides a duty-free quota of 3,000 tonnes per year for Ukrainian tomatoes, while volumes above the quota are subject to the regular most-favoured-nation regime. For Ukrainian cucumbers, Turkey reduces the duty by 75%, leaving 25% of the base rate payable.
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