Ukraine's ban on raw-log exports and the EU–Ukraine Association Agreement arbitration, 2015–2026
- The record does not name which of my species, waters, soils or forests were harmed.
- 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
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.
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.
- Ukrainian wood processors and furniture exporters — Keep raw timber in the country; ADPU argued that resuming log exports would raise domestic prices and cause shutdowns and job losses Interfax-Ukraine (press release, Association of Woodworking Enterprises of Ukraine)
- EU importers of logs — Barred from importing Ukrainian unprocessed timber; trade value not stated EU–Ukraine Association Agreement Arbitration Panel
What happened
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.
- 2005Law No. 2860-IV bans exports of ten rare and valuable species (8 September)
- 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
- 2017Ban applies to pine from 1 January
- 2018Law No. 2531-VIII on preventing illegal export of unprocessed timber (6 September)
- 2019EU requests consultations (15 January); consultations held (7 February); EU requests a panel (20 June)
- 2020Panel notes exchanged (28 January) and organisational meeting (29 January); final report (11 December); EU Delegation statement (14 December)
- 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
“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”
“The army needs wood for its needs”
Where accounts differ
Each party's account, side by side, with its source. The record does not settle these points; it shows them.
The measure supports domestic wood processing rather than protecting forests; sawn wood exports rose in parallel with the ban.
EU–Ukraine Association Agreement Arbitration PanelThe measures exercise its right to regulate its own level of environmental protection and combat illegal export.
EU–Ukraine Association Agreement Arbitration PanelThe 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 PanelThe 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 PanelFound the 2015 ban incompatible with Article 35 AA.
EU–Ukraine Association Agreement Arbitration PanelHow it looked
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
- The panel found the 2005 ban on ten species incompatible with Article 35 AA but justified under GATT Article XX(b) as necessary to protect plant life, so not in breach of Article 35.
- The panel found the 2015 temporary export ban incompatible with Article 35 AA and not justified under GATT Article XX(g).
- The panel recommended that Ukraine comply in good faith, taking into account AA Article 293.
- Forest figures recorded in the arbitration panel's final report: 10.4 million ha of forests, of which 9.4 million ha stocked (15.9% of territory); more than 44% of forested area certified.
- The statutory moratorium for non-pine species ended on 1 November 2025 and was replaced by Cabinet zero quotas to the end of 2026.
- ADPU argued that resuming log exports could cause a mass outflow of raw material, sharp domestic price rises, shortages for processors, plant shutdowns, job losses and lower export earnings from finished products and furniture.
Who gained
Reached nature or the ground
Gained elsewhere
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
Lawsuits and rulings
- 2019–2020Claimant wonEU v. Ukraine: restrictions on exports of certain wood products to the European UnionArbitration 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
What nature saw
Nature's report opens this page. Below: further outcomes measured on the ground.
What we don't know
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
Company or project
- 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
- Ukraine – wood export banEuropean Commission, DG Trade ·
- The history of the EU-Ukraine dispute on wood export banEuropean Commission, DG Trade · 2020-12-12
Courts
- Restrictions applied by Ukraine on exports of certain wood products to the European Union: Final ReportEU–Ukraine Association Agreement Arbitration Panel · 2020-12-11
Press and investigations
- Arbitration Panel finds Ukraine's wood export ban illegal, obliges to cancel it - EU DelegationInterfax-Ukraine · 2020-12-14
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