Illegal logging in Ukraine in 2023, according to forest users' data: an analytical report

In 2023, a total of 5,185 cases of illegal logging were documented, resulting in 30,262 cubic meters of illegally harvested timber. The proportion of officially documented illegally harvested timber relative to the total volume of timber harvested in Ukraine in 2023 was 0.2%.

Illegal logging is a detrimental phenomenon from both economic and environmental perspectives. In the context of Ukraine's European integration process, combating illegal logging is particularly crucial due to the requirements and standards of the European Union, which stipulate that illegally harvested timber must not enter the EU market. According to EU experts, timber harvesting in Ukraine carries significant risks regarding legality and requires additional verification of the supply chain when exporting timber products manufactured in Ukraine.

Experts from the NGO ForestCom, as part of the project "Combating Illegal Logging in Ukraine," supported by the International Programs division of the U.S. Forest Service, conducted a study to aggregate and analyze the volume of officially documented illegal logging by forest users of all agencies in Ukraine for 2023. ForestCom has been conducting such analytical studies of officially documented illegal logging in Ukraine for the past three years.

Data was identified according to publicly available information and collected through written surveys (sending requests) to well-known forest users and agencies. Due to russia's military aggression, the lack of public information on active forest users, ongoing decentralization, and forestry sector reforms, it was not possible to collect complete data on the volume of illegal logging for 2023.

The main challenges in collecting official data on the total volume of illegal logging remain the lack of a unified definition of the term "illegal logging," the absence of a uniform state reporting form that would obligate forest users of all ownership forms and types of subordination to submit the same information on indicators (including volumes) of detected illegal logging, and, most recently, the armed aggression of the russian federation and its consequences.

The study included data from:

*   The State Forest Resources Agency (within the territory controlled by the Ukrainian government).

*   A number of communal enterprises that are forest users (18 enterprises in 7 regions).

*   10 protected area institutions of the Ministry of Environmental Protection and Natural Resources (in 5 regions).

*   A portion of military forestry enterprises of the Ministry of Defense (4).

*   Other forest users.

The remaining agencies and forest users did not provide responses or provided them incompletely.

During the period of 2019-2022, there was an annual decrease in the level of illegal logging. However, in 2023, the level of illegal logging increased compared to 2022. This may be related to incomplete accounting of all cases due to hostilities and martial law and the ban on visiting forests in certain regions.

According to data from the State Forest Resources Agency, in 2023, indicators increased by 7,958.9 cubic meters, or 38.7%. It is important to note that this increase occurred primarily in regions affected by military actions, particularly the Kharkiv and Zaporizhzhia regions. A sharp decrease in the volume of illegal logging was noted in the Dnipropetrovsk region.

In 2023, 30,262 cubic meters of illegally harvested timber were officially documented, including:

*   In forests of the State Forest Resources Agency: 28,538.8 cubic meters (94.3%).

*   In communal forests: 924.2 cubic meters (3.1%).

*   In forests of the Ministry of Defense: 545 cubic meters (1.8%).

*   In forests subordinated to the Ministry of Environmental Protection: 208.1 cubic meters (0.7%).

*   In forests of other forest users (collectively): 45.93 cubic meters (0.2%).

Top Regions for Documented Illegal Logging (Based on 2023 Data Analysis from the State Forest Resources Agency):

The regions with the highest levels of documented illegal logging (based on an analysis of 2023 data from the State Forest Resources Agency, disaggregated by region) are as follows:

*   Kharkiv region – 6,993.7 cubic meters (24.5% of all illegal logging in forests managed by the Agency)

*   Zhytomyr (13.4%)

*   Lviv (10%)

*   Dnipropetrovsk (9.5%)

*   Zakarpattia (8.3%)

*   Zaporizhzhia (6.9%)

*   Kyiv (5.3%)

The indicator was less than 5% for all other regions.

The highest level of illegal logging among protected area institutions was recorded in the Rivne Nature Reserve – 66.115 cubic meters, which is 31.8% of the volume of illegal logging in forests managed by the Ministry of Environmental Protection and Natural Resources.

However, it is important to note that due to the military aggression of the Russian Federation against Ukraine, there is no information on illegal logging in temporarily occupied territories, particularly in the Zaporizhzhia, Luhansk, Mykolaiv, Donetsk, Kherson regions, and the Autonomous Republic of Crimea. The high indicators of illegal logging in the Kharkiv region may be related to military actions and detected cases of illegal logging after de-occupation.

Estimated areas of forests destroyed by the occupiers as of the end of 2022 are presented in the publication "Remote Monitoring of the Impact of the War on Forests in Ukraine."

The total amount of damages resulting from documented illegal logging in 2023 reached UAH 703.936 million, including:

*   UAH 580 million – damages caused to enterprises of the State Forest Resources Agency

*   UAH 57.09 million – to institutions of the Ministry of Environmental Protection and Natural Resources

*   UAH 49.03 million – to institutions of the Ministry of Defense

*   UAH 15 million – to communal forestry enterprises

*   UAH 2.9 million – to other forest users

From 2019 to 2023, there has been a gradual increase in the number of cases that are transferred to court, are under consideration, or have been considered by the court. The number of convicted persons has quadrupled (from 177 in 2019 to 717 in 2023), indicating an increase in the effectiveness of the judicial system and the level of inevitability of punishment for such violations.

The study again shows that the lack of a unified form and mandatory reporting on detected illegal logging, as well as the lack of a unified definition of the term "illegal logging," does not allow for a proper assessment of the volume of these loggings at the national level, to monitor the progress of investigations, and the level of accountability of those responsible.

In this regard, the NGO ForestCom proposes to amend Article 246 of the Criminal Code of Ukraine, in particular, regarding the definition of the concepts of "illegal felling" and "illegally harvested timber," as well as to adopt at the legislative level a draft unified reporting form for all forest users in Ukraine for reporting on the volume of illegal felling detected by them. We express our sincere gratitude to all departments and enterprises for providing data and facilitating the research, as well as gratitude to the U.S. Forest Service for financial support.

The full text of the analytical study "VOLUMES OF ILLEGAL LOGGING DOCUMENTED BY FOREST USERS OF UKRAINE IN 2023 (BASED ON PUBLIC REQUESTS)" - HERE