The Government has Introduced a Zero Quota for Timber Export

On October 31, 2025, the Cabinet of Ministers of Ukraine adopted Resolution No. 1399 [1](hereinafter referred to as the "Resolution”) introducing a zero export quota for unprocessed wood (except pine). According to the Resolution, the following products fall under the rules:

"Fuel wood in the form of logs, knots, brushwood, branches or in similar forms; wood chips or shavings” – classified according to UKT ZED codes 4401 11 00 00; 4401 12 00 00; 4401 21 00 00; 4401 22 10 00; 4401 22 90 00.

"Unprocessed timber, with or without bark or sapwood removed, roughly squared or unsquared, except pine” – classified under the UKT ZED code 4403.

The Resolution amends the Resolution of the Cabinet of Ministers of Ukraine No. 1481 dated December 24, 2024[2], which approves the lists of goods subject to licensing for export and import, as well as the quotas for 2025. Such resolutions are adopted annually and are valid until the end of the relevant calendar year.

The Government’s decision at the end of October was not accidental. The fact is that Ukraine introduced a moratorium on the export of unprocessed timber back in 2015. At that time, Law 325-VIII [3] (the "Law”) established a 10-year ban, effective from November 1, 2015. That is why the Resolution should ensure an uninterrupted restriction on the export of round timber and firewood, while the Verkhovna Rada decides the fate of the Law on the Timber Market[4], which should determine the next steps in this matter.

In addition, the decision on zero quotas is due to other factors. Ukraine has almost returned to pre-war levels of wood consumption per year, while logging volumes have decreased due to hostilities, mining, and the occupation of a large area. The deficit in the domestic market is aggravated by the difficult situation in the energy sector in winter, when consumer demand is only growing.[5]

However, the temporary export ban will be of greatest concern at the international level. This is due to the fact that it calls into question Ukraine’s fulfilment of international legal obligations: both to trading partners under free trade agreements and within the framework of the WTO. The norms prohibiting the export bans are provided, in particular, by Art. 35 of the Association Agreement with the EU, Art. 35 of the Political, Free Trade and Strategic Partnership Agreement between the United Kingdom of Great Britain and Northern Ireland and Ukraine, Art. 2.5 of the Free Trade Agreement between Ukraine and Canada and Art. 2.6 Free Trade Agreements between the Cabinet of Ministers of Ukraine and the Government of the State of Israel.

It is worth recalling that timber has already brought Ukraine into disputes with its partners. In particular, the EU initiated a dispute with Ukraine over a ban on timber exports in 2019. At that time, a specially created arbitration commission concluded that the ban on the export of timber violated Ukraine’s obligations under Art. 35 of the Association Agreement with the EU.

This decision remains relevant today, as it highlighted the weaknesses in the Ukrainian legal  argumentation under  WTO law, in particular, the justification for the prohibition under Art. XI:2(a), XX(g) and XXI GATT 1994.

The Resolution entered into force on the day following the day of its publication (November 1, 2025). The exception is fuel wood under code 4401, for which the Resolution comes into force 21 days after publication.