Illegal logging in Ukraine in 2022, according to forest users' data: an analytical report

According to the information provided by forest users/owners, the total volume of illegally logged timber in Ukraine in 2022 amounted to at least 24,327 cubic meters, accounting for 0.2% of the overall officially recorded timber harvesting level. 

Illegal logging is a negative phenomenon both economically and from an environmental perspective. It leads to significant loss of forest resources, economic damage to forest users, and disturbances to the condition and ecological functions of forests.

One of the key priorities of the NGO "Forest Initiatives and Community" (ForestCom) is combating illegal logging in Ukraine. As part of the project "Combating Illegal Logging in Ukraine", supported by the US Forest Service International Programs, our organization conducted research to collect and analyze the documented volumes of illegal logging by forest users from all agencies across Ukraine in 2022.

The data was gathered through a written survey (requests sent out) to officially registered and publicly available forest users and agencies. Due to the military aggression by Russia, lack of public information about active forest users, decentralization, and forestry reform, it was not possible to obtain complete data on the volumes of illegal logging in 2022.

The research covered data from:

- State Forest Resource Agency (on the territory controlled by the Ukrainian government)

- Several municipal entities functioning as forest users (17 entities in 6 regions)

- 36 institutions of the Nature Reserve Fund subordinated to the Ministry of Environment (in 14 regions)

- 2 institutions under the Ministry of Education in the Lviv region

- 1 institution under the Ukrainian Railways

- 1 regional forestry enterprise

Other agencies and forest users did not respond or only provided partial information.

The total volume of illegally harvested timber in Ukraine in 2022 amounted to at least 24,327 cubic meters, accounting for 0.2% of the overall timber harvesting level (according to statistical data). This is the lowest level in the last four years. For comparison, the highest volume of illegal logging in the past 20 years was recorded in 2019 - 125,279 cubic meters or 0.6% of the timber harvesting level. These changes can be attributed not only to a real decrease in illegal activities and the implementation of electronic timber tracking, but also to the incomplete recording of all cases due to ongoing hostilities and a state of war, restrictions on forest access, and limitations on the work of the State Ecological Inspection.

The majority of illegal logging was found in the forests managed by the State Forest Resource Agency - 84.6%, significantly less in institutions of the Nature Reserve Fund - 9.5%, in municipal forests - 6%, and in forests managed by the Ministry of Education - 0.01%.

Based on the extent of recorded illegal logging, the following regions had the highest rates:

- Dnipropetrovsk Regional Forestry Enterprise - 6840 cubic meters (33.2% of the total volume within the State Forestry Agency)

- Kharkiv Regional Forestry Enterprise - 3496 cubic meters (17.0%)

- Zakarpattia Regional Forestry Enterprise - 2343 cubic meters (11.4%)

- Kyiv Regional Forestry Enterprise - 1856 cubic meters (9.0%)

The highest proportion of illegal logging relative to legal timber harvesting was observed in Dnipropetrovsk and Kherson Regional Forestry Enterprises - 10% and 5%, respectively.

The highest level of illegal logging recorded among institutions of the Nature Reserve Fund was in Uzhanskyi National Nature Park (Zakarpattia Region) - 2088 cubic meters, accounting for 90.7% of the total logging volume within the Fund's forests. These volumes are comparable to the data provided by the State Forestry Agency for Zakarpattia Regional Forestry Enterprise and unfortunately indicate a fairly high level of illegal logging in the Carpathian region.

Illegal logging activities have caused significant financial damage, totaling 258.1 million hryvnias. The breakdown of damages includes:

- 186.7 million hryvnias to State Forest Resource Agency enterprises

- 39.2 million hryvnias to institutions of the Ministry of Environmental Protection and Natural Resources

- 32.1 million hryvnias to municipal forest management enterprises

- 20.6 thousand hryvnias to Ministry of Education institutions.

Our research has shown that the absence of a unified reporting format and reporting requirements for detected illegal logging, as well as the lack of a uniform definition of "illegal logging," that hinders proper assessment of the extent of these activities at the national level, monitoring of investigations, and accountability.

In light of these challenges, the NGO ForestCom proposes amending Article 246 of the Criminal Code of Ukraine to define the terms "illegal logging" and "illegally obtained timber," as well as implementing a standardized reporting form for all forest users in Ukraine to report on the volumes of detected illegal logging.

We express our sincere gratitude to all agencies and enterprises for providing data and supporting our research, as well as our appreciation to the US Forest Service for their financial support.

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You can access the full text of the analytical research VOLUMES OF ILLEGAL LOGGING DOCUMENTED BY FOREST USERS OF UKRAINE IN 2022 (BASED ON PUBLIC REQUESTS) - ANALYTICAL REPORT

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