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Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Law, regulation and treaties · Ukraine · 2015–2026

Ukraine's ban on raw-log exports and the EU–Ukraine Association Agreement arbitration, 2015–2026

Nature's voice · report
No measurement of the harm done to me here is on record.
Did nature suffer? Not measured. Disputed
Not on record
  • The record does not name which of my species, waters, soils or forests were harmed.
What the record lacks: 4 none on record · 2 not measured · 3 disputed · 1 unclear See the gaps
Accounts of the harm differ
Purpose of the 2015 ban on unprocessed timber exports

In 2015 Ukraine banned exports of unprocessed timber for ten years. An arbitration panel under the EU–Ukraine Association Agreement ruled on 11 December 2020 that the 2015 ban breached Article 35 of the Agreement; in 2025–2026 the Cabinet replaced the expiring ban with zero export quotas.

Ruled in breach of Art. 35 AA2015 ban on unprocessed timber exports
EU–Ukraine Association Agreement arbitration panel, final report of 11 December 2020; the 2005 ban on ten species was found justified. Ukraine's Cabinet set zero export quotas for 2025 and 2026.

Status As of December 2025: Cabinet zero export quotas for unprocessed and fuel wood run to the end of 2026; no repeal of the 2015 ban by the Rada is on record and the EU response is not on record.

What?
Ukraine's ten-year ban on exports of unprocessed timber, adopted in 2015, was found by an EU–Ukraine Association Agreement arbitration panel on 11 December 2020 to breach Article 35 of the Agreement, while the 2005 ban on ten species was found justified. In 2025–2026 the Cabinet replaced the expiring ban with zero export quotas. EU–Ukraine Association Agreement Arbitration Panel
Where?
Ukraine-wide; the arbitration was held in Lugano, Switzerland, between the European Union and Ukraine. EU–Ukraine Association Agreement Arbitration Panel
When?
Laws of 8 September 2005 and 9 April 2015; consultations 7 February 2019; panel request 20 June 2019; final report 11 December 2020; zero quotas from 31 October 2025, extended on 31 December 2025 to the end of 2026. EU–Ukraine Association Agreement Arbitration Panel
Who?
Gained
Lost
Harmed
None on record
Why?
Ukraine presented the ban as forest protection and a measure against illegal export; the EU argued it supported domestic processors and the panel found it not justified under GATT Article XX(g). EU–Ukraine Association Agreement Arbitration Panel
How?
The EU requested consultations on 15 January 2019 and a panel on 20 June 2019 under Article 307 AA; the panel delivered its final report on 11 December 2020 and, after the statutory moratorium for non-pine species expired on 1 November 2025, the Cabinet set zero export quotas through licensing. Interfax-Ukraine
6 of 6 questions answered from the record

What happened

The record, in order.

Ukraine banned exports of ten rare and valuable tree species in 2005 (Law No. 2860-IV) and, on 9 April 2015, adopted Law No. 325-VIII, a ten-year ban on exports of unprocessed timber (HS 4403): from 1 November 2015 for species other than pine and from 1 January 2017 for pine. Law No. 2531-VIII of 6 September 2018 concerned preventing illegal export of unprocessed timber. The ban was presented as forest protection and a measure against illegal export.

The European Union requested consultations on 15 January 2019; they were held on 7 February 2019 without resolving the matter, and the EU requested a panel on 20 June 2019. The arbitration was held under Article 307 of the EU–Ukraine Association Agreement (AA), in Lugano; it was the first EU trade dispute under a bilateral agreement. The panel was Christian Häberli (chair), Viktor Muraviov and Giorgio Sacerdoti. The EU said the case was not about whether Ukraine could adopt measures protecting its forests and argued that sawn wood exports rose in parallel with the 2015 ban, so the measure concerned supporting domestic wood processing. Ukraine said the measures were an exercise of its right to regulate its own level of environmental protection, that the panel lacked jurisdiction because this was a Chapter 13 case, and that Article 35 did not apply until the end of the ten-year transition at the end of 2025.

In its final report of 11 December 2020 the panel found that the 2005 ban was incompatible with Article 35 AA but justified under Article XX(b) of the GATT 1994 as necessary to protect plant life, and that the 2015 ban was incompatible with Article 35 and not justified under Article XX(g) of the GATT 1994. It recommended that Ukraine comply in good faith, taking into account AA Article 293 on forest law enforcement and governance and trade in legal and sustainable forest products. The EU Delegation said Ukraine was expected to terminate the export ban as soon as possible; Deputy Minister Taras Kachka said the panel recognised Ukraine's right to restrict wood exports under certain circumstances.

On 31 October 2025, as the statutory moratorium for non-pine species ended on 1 November 2025, the Cabinet set a zero export quota (licensing) for unprocessed timber until the end of 2025; on 31 December 2025 it extended zero quotas for unprocessed and fuel wood to the end of 2026. The Association of Woodworking Enterprises of Ukraine (ADPU) argued that resuming log exports could cause a mass outflow of raw material, sharp domestic price rises, plant shutdowns and job losses. Prime Minister Yuliia Svyrydenko said the ban was a necessary step to protect people in winter, preserve enterprises and reduce the burden on the environment, and that harvesting had fallen during the full-scale invasion.

  1. 2005Law No. 2860-IV bans exports of ten rare and valuable species (8 September)
  2. 2015Law No. 325-VIII bans exports of unprocessed timber for ten years (9 April); in force from 1 November 2015 for species other than pine
  3. 2017Ban applies to pine from 1 January
  4. 2018Law No. 2531-VIII on preventing illegal export of unprocessed timber (6 September)
  5. 2019EU requests consultations (15 January); consultations held (7 February); EU requests a panel (20 June)
  6. 2020Panel notes exchanged (28 January) and organisational meeting (29 January); final report (11 December); EU Delegation statement (14 December)
  7. 2025Cabinet sets zero export quota to the end of 2025 as the moratorium for non-pine species ends (31 October); extends zero quotas to the end of 2026 (31 December)

What was said

Claims, in the words of those who made them.

“not about whether Ukraine is entitled to adopt measures for protecting its forests”

“confirming that the measure is essentially concerned with supporting Ukraine's domestic wood processing industry, rather than protecting Ukrainian forests”

“a mere exercise of [Ukraine's] right to regulate its own level of environmental protection”

“not justified under Article XX(g) of the GATT 1994. because that export ban is not 'relating to the conservation of exhaustible resources.made effective in conjunction with restrictions on domestic production or consumption.'”

“Ukraine is expected to terminate the export ban as soon as possible”

“a necessary step to take care of people in winter, preserve the work of our enterprises and reduce the burden on the environment”

Yuliia Svyrydenko, Prime Minister of Ukraine, on the export ban · 31 October 2025 · translated from Ukrainian · Interfax-Ukraine

“The army needs wood for its needs”

Yuliia Svyrydenko, Prime Minister of Ukraine · 31 October 2025 · translated from Ukrainian · Interfax-Ukraine

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Purpose of the 2015 ban on unprocessed timber exports
International bodies
European Union

The measure supports domestic wood processing rather than protecting forests; sawn wood exports rose in parallel with the ban.

EU–Ukraine Association Agreement Arbitration Panel
Government and regulators
Ukraine

The measures exercise its right to regulate its own level of environmental protection and combat illegal export.

EU–Ukraine Association Agreement Arbitration Panel
Courts
Arbitration panel

The 2015 ban was not justified under GATT Article XX(g) because it was not made effective in conjunction with restrictions on domestic production or consumption.

EU–Ukraine Association Agreement Arbitration Panel
Whether the panel had jurisdiction and Article 35 applied
Government and regulators
Ukraine

The case is plainly a Chapter 13 case, and Article 35 does not apply until the end of the ten-year transition, at the end of 2025.

EU–Ukraine Association Agreement Arbitration Panel
Courts
Arbitration panel

Found the 2015 ban incompatible with Article 35 AA.

EU–Ukraine Association Agreement Arbitration Panel

How it looked

What was shown, beside what was recorded.

Shown

  • The ban is a measure of forest protection and against illegal export; Ukraine's forests cover 10.4 million ha, 15.9% of the territory with 9.4 million ha stocked, against an optimal cover stated as 20%, and standing stock rises by an average of 35 million m3 a year.
    Ukraine, as recorded in the panel report · EU–Ukraine Association Agreement Arbitration Panel
  • Zero quotas let strategic raw materials stay in Ukraine for domestic processing.
    Prime Minister Yuliia Svyrydenko, 31 December 2025 · Interfax-Ukraine

Recorded

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
No figure published.

Gained elsewhere

Not totalled
Currency: · Window: . All figures cover the same period. * Estimate built from cited figures.

Responses on record

  • European Commission (DG Trade) (12 December 2020): The ruling means Ukraine must end the export ban as soon as possible. · European Commission, DG Trade
  • EU Delegation to Ukraine (14 December 2020): Ukraine is expected to terminate the export ban as soon as possible; first EU trade dispute under a bilateral agreement. · Interfax-Ukraine
  • Ministry of Economy of Ukraine (Deputy Minister Taras Kachka) (December 2020): The panel recognised Ukraine's right to restrict wood exports under certain circumstances. · Interfax-Ukraine
  • Prime Minister of Ukraine (Yuliia Svyrydenko) (31 October and 31 December 2025): The ban is a necessary step to care for people in winter, preserve enterprises and reduce the burden on the environment; zero quotas keep strategic raw materials in Ukraine for domestic processing. · Interfax-Ukraine
  • Association of Woodworking Enterprises of Ukraine (October 2025): Resuming log exports could cause a mass outflow of raw material, price rises, plant shutdowns and job losses. · Interfax-Ukraine (press release, Association of Woodworking Enterprises of Ukraine)

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

  1. 2019–2020Claimant won
    EU v. Ukraine: restrictions on exports of certain wood products to the European Union
    Arbitration panel under Article 307 of the EU–Ukraine Association Agreement, Lugano · Arbitration · European Union → Ukraine

    Final report of 11 December 2020: the 2005 export ban on ten species was incompatible with Article 35 AA but justified under GATT Article XX(b); the 2015 temporary export ban was incompatible with Article 35 and not justified under GATT Article XX(g). The panel recommended good-faith compliance, taking into account AA Article 293. None on record: repeal of the 2015 ban by the Verkhovna Rada. EU–Ukraine Association Agreement Arbitration Panel

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Ruling
11 Dec 2020
2015 ban in breach of Art. 35 AA; 2005 ban justified
Ban period
10 years
From 2015; non-pine species to 1 November 2025
Export quotas
Zero
Unprocessed and fuel wood to the end of 2026

What we don't know

Undisclosed, unproven, untried: recorded as data.

Nature

  • Not measured Harm to nature: No independent ecological evaluation is on record.
  • Disputed Purpose of the 2015 ban on unprocessed timber exports

Accounts

  • Disputed Whether the panel had jurisdiction and Article 35 applied

Record

  • Not measured Not measured: logging volumes before and after the ban; the panel ruled on legal justification and did not assess the effect of the ban on forests.
  • None on record None on record: value of the EU log imports affected; the panel report sections and the European Commission pages do not state it.
  • None on record None on record: repeal of the 2015 ban by the Verkhovna Rada.
  • None on record None on record: EU response to the 2025–2026 zero export quotas.
  • Unclear Unclear: final status of bills No. 13223 and No. 13227-d on the timber market in 2026.
  • Disputed Figures differ: the date of the panel request is 20 June 2019 in the panel report; European Commission pages give different dates.
  • None on record None on record: compliance step by Ukraine listed on the European Commission dispute page.

Did the harm stop?

The 2015 ban remained in effect after the December 2020 report; the statutory moratorium for non-pine species ended on 1 November 2025 and was replaced by Cabinet zero export quotas running to the end of 2026.

Who paid?

None on record.

Sources

Voices on record: ✓ Company or project✓ Government and regulators✓ Courts✓ Press and investigations— Communities and civil society— Researchers

Company or project

  1. Moratorium end and zero-quota proposal (press release of the Association of Woodworking Enterprises of Ukraine)
    Interfax-Ukraine (press release, Association of Woodworking Enterprises of Ukraine) · 2025-10

Government and regulators

  1. Ukraine – wood export ban
    European Commission, DG Trade ·
  2. The history of the EU-Ukraine dispute on wood export ban
    European Commission, DG Trade · 2020-12-12

Courts

Connected cases

Related matters, and cases linked to this one through the same organisations, with the role each played in both.

Law and courts

Arbitration
A private dispute process in which an appointed arbitrator, instead of a court, decides the case.

Science and environment

Hectare (ha)
A unit of area equal to 10,000 square metres, about 2.5 acres. 100 hectares make one square kilometre.