Ukrainian soy producers express deep concern over the European Commission’s proposal to classify soy as a raw material with a high risk of indirect land use change (high ILUC-risk) under the EU Renewable Energy Directive (RED).
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According to the Ukrainian Agribusiness Club Association (UACBA), if this proposal comes into effect, it will have a significant negative impact on Ukraine’s agricultural sector, the European plant protein market, and the broader strategic food security of the EU.
The UACBA has sent a document to the EU institutions explaining the consequences of amendments to Regulation (EU) 2019/807. In particular, the document will introduce additional certification requirements for compliance with low ILUC-risk, effectively imposing a significant additional administrative and financial burden on producers and processors, especially in conditions of military challenges, logistical disruptions, and rising production costs.
According to the UACBA, “Ukrainian soy already meets high standards of traceability and sustainability. Ukraine is officially recognized as a low-risk country under the EU Regulation to prevent deforestation (EUDR), so the introduction of additional classification as high ILUC-risk will essentially duplicate regulatory requirements and create unjustified barriers for Ukrainian agro-producers.”
“Ukraine remains the largest soy producer in Europe. By 2025, soy production in Ukraine is expected to reach 5.6-5.7 million tons, while Ukrainian soy production continues to play an important role in ensuring the protein and food security of the European Union. In 2025, Ukraine’s share in EU soybean oil imports increased to 66%, while 43% of Ukrainian soybean oil exports were directed to the EU market,” the association emphasizes.
The UACBA stresses that Ukrainian soy is not only an important component of the European plant protein market but also a strategic alternative to imports from regions associated with increased environmental risks. Ukrainian soy production is non-GMO, fully traceable, and produced without risks associated with deforestation.
At the same time, the proposed approach, experts believe, contradicts a number of key strategic goals of the European Union, including:
– strengthening EU food and protein autonomy;
– the future EU Protein Plan;
– supporting regional production of plant proteins;
– the goal of simplifying and harmonizing regulatory procedures.
Ukraine’s agricultural sector calls on the European Parliament and the EU Council not to support the draft delegated act in its current version within the official review period.
“As a candidate country for EU accession, Ukraine should be considered a European supplier of soy in any future EU regulatory initiatives related to the status of soybean vegetable oil as a feedstock for sustainable biofuels under the EU Renewable Energy Directive,” concluded the UACBA.