The UNBA warned of the risk of customs barriers for Ukrainian paper and furniture

Ukraine’s anti-deforestation rules are intended to preserve export access to the EU market. However, without paper and furniture on the list of goods, without effective sanctions, and with enforcement beginning only in 2030, these rules could hinder that goal.

This conclusion was reached by the UNBA Committee on agricultural, land and environmental law following an analysis of Draft Law No. 15352 dated June 25, 2026 «On the trade in goods linked to deforestation and/or forest degradation», which the Verkhovna Rada adopted as a basis.

According to the authors of the legislative initiative, the draft is intended to implement Regulation (EU) 2023/1115 (EUDR), which requires confirmation that certain types of raw materials (palm oil, livestock, soybeans, coffee, cocoa, timber, rubber) and products made from them are not linked to deforestation after December 31, 2020.

The document stipulates that operators and traders will collect geolocation data on production sites and conduct due diligence on goods. To this end, it proposes using electronic systems based on the State Agrarian Register and the exporter’s electronic account. The bill also proposes amending the Forest Code to ensure the effective organization and scientifically sound management of forestry, as well as to introduce a certificate of origin for timber and timber products through amendments to the laws «On the specifics of state regulation of business activities related to the sale and export of timber» and «On the list of permits in the sphere of economic activity».

The need for such changes stems from the need to maintain Ukrainian products’ access to the EU market and to comply with the conditions of the Ukraine Facility program.

UNBA acknowledged that the draft law is an important step toward European integration, while also pointing out a number of legal shortcomings.

The key concern relates to the list of goods. The draft law covers only certain commodity groups of the Ukrainian Classification of Goods for Foreign Economic Activity (UKT ZED), and wood products are included only within Group 44. The EU regulation, by contrast, explicitly covers: wood pulp (Group 47); paper and cardboard (Group 48); and furniture (Group 94). According to advocates, without these groups, Ukrainian pulp and paper and furniture products risk facing a de facto customs embargo.

The relevant Committee of the UNBA also drew attention to the rules for certifying the origin of timber. Under the draft law, the certificate would confirm only the legality of harvesting. However, EU regulations require proof that the forest was not destroyed after December 31, 2020. The UNBA proposes adding this criterion to the certificate and aligning it with the declaration of due diligence.

Separately, the UNBA expressed concerns regarding sanctions. The draft law provides only for fixed administrative fines. The EU regulation requires effective, proportionate, and dissuasive measures: confiscation of products and proceeds, bans on participation in public procurement, and fines of at least 4% of annual turnover.

It is also noted that the provisions on control (Articles 17–25) will not take effect until January 1, 2030. This conflicts with the National Program for the Adaptation of Legislation and Ukraine’s negotiating position. The date must be moved to 2027 or a postponement must be agreed upon with the European Commission.

In addition, the comments address support for small and medium-sized businesses, deadlines for notifying parties of non-compliance risks, the risk assessment scale, and simplified inspection procedures. The advocates also propose introducing a mechanism for submitting «reasoned concerns» and ensuring the compatibility of the exporter’s electronic portal with the EU’s information system.

The UNBA is convinced that addressing these shortcomings will ensure compliance with European standards, protect Ukrainian exports and contribute to a positive assessment of Ukraine in EU accession negotiations.

The full text of the comments and proposals can be viewed at this link.