Recent changes
- The Wassenaar Arrangement Secretariat issued the corrected 2025 Lists (WA-LIST (25) 1 Corr.)
- The version of Law No. 549-IV as amended by Law No. 4577-IX took effect: Art. 20 on the simplified procedure for transfers under Ukraine’s international treaties was amended, the procedure to be set by the Cabinet of Ministers
Ukraine’s export control law speaks a language of its own: “international transfers”, a “conclusion”, a “general permit”, “goods” that include services. There is no official English translation, and a literal one often lands on an EU or Wassenaar term that means something else. A foreign partner then reads into a contract or a permit something it does not say.
This page sets out 38 terms of Law of Ukraine No. 549-IV on State Control over International Transfers of Military and Dual-Use Goods: 33 from Article 1 and 5 from other articles. Each comes with an English rendering, its meaning under the text of the Law, the closest EU and Wassenaar term, and the difference between them. Everything has been checked against the texts; the links lead to the primary sources.
Before you translate
- There is no official English translation of the Law. The Verkhovna Rada publishes only a summary, marked as outdated, which calls the statute the Law “On the State Control over International Transfers of Military and Dual-Use Commodities”. The English renderings in the tables are our suggestion: where a Ukrainian term matches an EU or Wassenaar term in substance, we use that term; where it does not, we keep a literal translation so as not to give it a borrowed meaning. The only official English text in which the state itself names these concepts is Ukraine’s replies to the OSCE questionnaire on arms exports (the latest dated 28 June 2024); the wording used there is shown under the term.
- “Goods” also means services and technology. Article 1 places services and technology within military goods, and technical assistance within dual-use goods. In EU instruments services are not goods: brokering and technical assistance are regulated as separate activities.
- An export can happen without crossing the border. Handing goods to a foreigner in Ukraine, or disclosing technology to that person, is already an export. In Regulation (EU) 2021/821 the definition of export turns on leaving the customs territory (Art. 2(2)).
- A “general permit” is not a general authorisation. In the EU a general authorisation may be used by any exporter who meets its conditions. The Ukrainian general permit is issued to one entity for supplies to a named end-user; the Ukrainian open permit is closer to the EU global authorisation.
- A “conclusion” is an authorisation. It grants the right to transit, to import or export temporarily, and to negotiate. Negotiating a contract for military goods also requires a conclusion (Arts 1, 18).
- Brokering includes financing and transport. Under the Ukrainian definition, intermediary activity is any act that facilitates a transfer of military goods, including financing, transport and freight forwarding. Regulation 2021/821 excludes precisely those services as ancillary (Art. 2(7)).
- Imports are controlled too, but not all of them. Import and transit of military goods always require a permit or a conclusion (Procedure No. 1807, paras 20, 26). For dual-use goods, an import permit and a transit conclusion are needed only for a closed set of entries on the Unified List (Procedure No. 86, para. 12), whereas export, temporary export and re-export always need one. Regulation 2021/821 does not control imports.
- “Re-export” has two meanings. In the Law it is the removal from Ukraine of goods previously imported. In the Wassenaar documents re-export is an onward transfer by the importing state; in Ukrainian law that undertaking sits in the end-user certificate.
- How to write it in a contract. In our view, where the meanings diverge the Ukrainian term is best given in brackets after the English one: “general permit (генеральний дозвіл)”, “conclusion (висновок)”. A party used to EU terms then sees that a Ukrainian document is meant.
Terms by group
Article numbers in the cells refer to Law No. 549-IV as in force from 5 October 2025. EU and Wassenaar terms are given in the original.
- Transactions (9)
- Controlled items (10)
- Parties and end use (5)
- Documents (9)
- Procedures and the authority (5)
Transactions
| Term · in Ukrainian | Meaning under the Ukrainian Law | EU: term and difference | Wassenaar Arrangement |
|---|---|---|---|
| international transfers of goodsміжнародні передачі товарів · mizhnarodni peredachi tovariv | Export, import, re-export, temporary export and import, transit through Ukraine, and any other transfers of goods carried out outside Ukraine. Law No. 549-IV, Art. 1 | No umbrella term: Regulation (EU) 2021/821 controls exports, brokering, technical assistance, transit and transfer separately (Art. 1). In Directive 2009/43/EC “transfer” means only a movement of a defence-related product between Member States (Art. 3(2)). | The best-practice compendium uses “transfers” without defining it; the Lists contain no definition. |
| exportекспорт · eksport | Sale or other transfer of goods to foreign entities, whether or not the goods cross the customs border of Ukraine. It covers a transfer inside Ukraine to a foreigner or an embassy, a transfer of the right to control the goods, disclosure of technology to a foreigner, and actual shipment for onward movement abroad. Law No. 549-IV, Art. 1 | “Export” in Regulation 2021/821 is the customs export procedure, re-export, outward processing and the transmission of software or technology by electronic means to a destination outside the EU customs territory (Art. 2(2)). The definition turns on leaving the territory; a transfer to a foreigner inside it is not covered. | The Lists give no definition. The 2006 Best Practices on intangible transfers of technology leave it to national law to determine what constitutes such an export and when it occurs (section A.1). Compendium, p. 13. |
| re-exportреекспорт · reeksport | Sale or other transfer to foreign entities, with or without removal from Ukraine, of goods previously imported into Ukraine. It forms part of “export”. Law No. 549-IV, Art. 1 | Re-export within the meaning of Article 270 of the Union Customs Code is likewise part of “export” (Regulation 2021/821, Art. 2(2)(b)). | A different meaning: “subsequent transfer (re-export)” in the 2011 Guidelines is an onward transfer of weapons by the importing state to third governments, which needs the prior authorisation of the original exporting government (paras 1, 2(a)). Compendium, pp. 27–28. |
| importімпорт · import | Purchase or other receipt of goods from foreign entities, whether or not the goods are brought into Ukraine, including purchases for their own use by branches of Ukrainian organisations and diplomatic missions abroad. The right to import is granted by a permit. For military goods it is always required (Procedure No. 1807, para. 20); for dual-use goods, only for the entries named in Procedure No. 86 (para. 12) and where the goods are imported under an international import certificate. Law No. 549-IV, Art. 1 | Regulation 2021/821 does not control imports: it covers exports, brokering, technical assistance, transit and transfer (Art. 1). Common Position 2008/944/CFSP concerns export licences (Art. 1). | The Arrangement concerns export controls; neither the Lists nor the compendium defines import. |
| transitтранзит · tranzyt | Carriage of goods from one foreign state to another through Ukraine, provided that title or the right of possession and use does not pass to another person in Ukraine. The right to transit is granted by a conclusion: for military goods it is always required (Procedure No. 1807, para. 26); for dual-use goods, only for the entries named in Procedure No. 86 (para. 12). Law No. 549-IV, Art. 1 | “Transit” is the transport of non-Union dual-use items through the EU customs territory to a destination outside it (Regulation 2021/821, Art. 2(11)). No general authorisation is required: the competent authority may prohibit a transit or, in individual cases, require an authorisation on the grounds listed in Art. 4(1) (Art. 7). | The 2015 Guidelines on transit or trans-shipment recommend authority to control such items and, where appropriate, to require authorisations; they do not define transit. Compendium, p. 39. |
| temporary exportтимчасове вивезення товарів · tymchasove vyvezennia tovariv | Removal of goods from Ukraine to a foreign state with their subsequent return to Ukraine. It is authorised by a conclusion, not a permit. Law No. 549-IV, Art. 1 | Regulation 2021/821 has no separate term; outward processing is part of “export” (Art. 2(2)(c)). Directive 2009/43/EC lists transfers for demonstration, evaluation, exhibition, maintenance and repair among the cases for general transfer licences (Art. 5(2)(c)–(d)). | Neither the Lists nor the compendium uses the term. |
| temporary importтимчасове ввезення товарів · tymchasove vvezennia tovariv | Bringing goods into Ukraine from a foreign state with their subsequent removal from Ukraine. It is authorised by a conclusion; for dual-use goods, only in the cases named in Procedure No. 86 (para. 12). Law No. 549-IV, Art. 1 | None: Regulation 2021/821 does not control imports (Art. 1). | Neither the Lists nor the compendium uses the term. |
| intermediary (brokering) activityпосередницька (брокерська) діяльність · poserednytska (brokerska) diialnist | Any acts of a Ukrainian business entity that facilitate international transfers of military goods, including financing, transport or freight forwarding, whatever the origin of the goods and wherever the activity takes place. Law No. 549-IV, Art. 1 | For dual-use items, “brokering services” means negotiating or arranging transactions for supply from one third country to another; transport, financial services, insurance and advertising are excluded as ancillary services (Regulation 2021/821, Art. 2(7)). For arms see Common Position 2003/468/CFSP, Art. 2(3): again transfers between third countries. | 2003 Best Practices (amended 2016): negotiating or arranging contracts, selling, trading or arranging the transfer of arms from one third country to another; a state may extend the definition to exports from its own territory (para. 1(a)). Compendium, p. 32. |
| embargo (full or partial)ембарго (повне або часткове) · embarho (povne abo chastkove) | A prohibition or restriction on exports of goods to states designated by international organisations of which Ukraine is a member, or to states in respect of which a corresponding national policy is pursued. Law No. 549-IV, Art. 1 | “Arms embargo” means an arms embargo imposed by a Council decision or common position, an OSCE decision or a binding UN Security Council resolution (Regulation 2021/821, Art. 2(19)). National policy is not a basis under the definition. | The 2003 Statement on non-listed items refers to a binding UN Security Council arms embargo and a regional arms embargo binding on the state or voluntarily accepted by it. Compendium, p. 57. |
Controlled items
| Term · in Ukrainian | Meaning under the Ukrainian Law | EU: term and difference | Wassenaar Arrangement |
|---|---|---|---|
| goodsтовари · tovary | Military goods and dual-use goods. By their own definitions both categories also include services and technology. Law No. 549-IV, Art. 1 | “Items”: “dual-use items” include software and technology (Regulation 2021/821, Art. 2(1)). For arms the terms are “military technology and equipment” (Common Position 2008/944) and “defence-related products” (Directive 2009/43, Art. 3(1)). | “Goods and technologies” in the title of the Arrangement and of the list; “items” in the text of the lists. |
| military goodsтовари військового призначення · tovary viiskovoho pryznachennia | Collectively or separately: military products, military services and military technology. They are listed in the annex to Procedure No. 1807. Law No. 549-IV, Art. 1 | “Military technology and equipment” on the EU Common Military List (Common Position 2008/944, Art. 1(1)); “defence-related products” (Directive 2009/43, Art. 3(1)). Services are not a kind of goods: the Common Position covers applications for physical exports, brokering licences, transit and intangible transfers (Art. 1(2)). | The entries of the Munitions List (ML1–ML22). |
| military productsвироби військового призначення · vyroby viiskovoho pryznachennia | Armaments, ammunition, military and special equipment, special components for their production, explosives, and materials and equipment specially designed for the development, production or use of such products. Law No. 549-IV, Art. 1 | No separate term: the items on the EU Common Military List referred to in Common Position 2008/944 (Arts 1(1), 12). | Equipment on the Munitions List; software (ML21) and technology (ML22) are separate entries there. |
| military servicesпослуги військового призначення · posluhy viiskovoho pryznachennia | Provision to foreign legal or natural persons, in Ukraine or abroad, of services (including intermediary or brokering services) relating to the development, production, testing, repair, maintenance, modernisation, operation, sale, storage, acquisition or use of military products or technology, and of financing for such work. Law No. 549-IV, Art. 1 | There is no category of “military services”. The closest are brokering activities (Common Position 2003/468) and intangible transfers of software and technology (Common Position 2008/944, Art. 1(2)). | No category of services; “technical assistance” is a form of technology (Lists, definition of “Technology”; ML22). |
| military technologyтехнології військового призначення · tekhnolohii viiskovoho pryznachennia | Special information in any form, other than publicly available information, necessary for the development, production or use of military products and for the provision of military services. It may be provided as technical data or technical assistance. Law No. 549-IV, Art. 1 | Common Position 2008/944 covers licences for intangible transfers of software and technology by electronic media, fax or telephone (Art. 1(2)). | “Technology” is specific information necessary for the development, production or use of a product, in the form of technical data or technical assistance (Lists, definitions; ML22). ML22 does not apply to technology “in the public domain”, “basic scientific research” or the minimum necessary for patent applications (Note 2); the Ukrainian law names publicly available information only. |
| technical dataтехнічні дані · tekhnichni dani | Designs, plans, drawings, schemes, diagrams, models, formulae, specifications, software, manuals and instructions on paper or other media, including electronic media. Law No. 549-IV, Art. 1 | Article 2 of Regulation 2021/821 has no definition; technology there is part of “dual-use items” (Art. 2(1)). | “Technical data” may take forms such as blueprints, plans, diagrams, models, formulae, algorithms, tables, engineering designs and specifications, manuals and instructions (Lists, definition of “Technology”, Technical Note 1). Software is not among them: “software” is defined separately. |
| technical assistanceтехнічна допомога · tekhnichna dopomoha | Instruction, consultations, skills improvement, training and practical mastering of working methods. In the Law this is a form of military technology; dual-use goods have a separate term (see below). Law No. 549-IV, Art. 1 | “Technical assistance” means any technical support related to repairs, development, manufacture, assembly, testing or maintenance, in forms such as instruction, advice, training, transmission of working knowledge or consulting (Regulation 2021/821, Art. 2(9)). It is an activity distinct from export; an authorisation is required where the provider has been informed of the uses listed in Art. 4(1) (Art. 8). | “Technical assistance” may take forms such as instruction, skills, training, working knowledge and consulting services, and may involve the transfer of technical data (Lists, definition of “Technology”, Technical Note 2). |
| basic technologiesбазові технології · bazovi tekhnolohii | Technologies that determine the operating principle and use of equipment, and elements of technology without which military equipment cannot be created and used. The term is defined in Article 1 and is not used elsewhere in the Law. Law No. 549-IV, Art. 1 | Regulation 2021/821 does not use the term. | The Lists do not use the term. It should not be confused with “basic scientific research”, to which technology controls do not apply. |
| dual-use goodsтовари подвійного використання · tovary podviinoho vykorystannia | Certain products, equipment, materials, software and technology not specially designed for military use, and related services (technical assistance), which can be used for military or terrorist purposes or to create weapons of mass destruction. They are listed in the Unified List of Dual-Use Goods. Law No. 549-IV, Art. 1 | “Dual-use items” means items, including software and technology, which can be used for both civil and military purposes (Regulation 2021/821, Art. 2(1)). The definition mentions neither terrorist purposes nor services. | The List of Dual-Use Goods and Technologies, Categories 1–9. |
| dual-use services (technical assistance)послуги (технічна допомога) подвійного використання · posluhy (tekhnichna dopomoha) podviinoho vykorystannia | Provision to foreign legal entities or foreigners, in Ukraine or abroad, of technical support related to the repair, development, production, use, testing, modernisation or other servicing of controlled systems, equipment, software and technology. It is a kind of dual-use goods. Law No. 549-IV, Art. 1 | “Technical assistance” and “provider of technical assistance” (Regulation 2021/821, Art. 2(9)–(10)); a provider includes a person assisting a resident of a third country temporarily present in the EU. An authorisation is required only under the conditions of Art. 8. | “Technical assistance” as a form of technology (Lists, definition of “Technology”, Technical Note 2). |
Parties and end use
| Term · in Ukrainian | Meaning under the Ukrainian Law | EU: term and difference | Wassenaar Arrangement |
|---|---|---|---|
| entity engaged in international transfers of goodsсуб’єкт здійснення міжнародних передач товарів · subiekt zdiisnennia mizhnarodnykh peredach tovarivIn Ukraine’s OSCE replies: registered entity; subject of international transfers of goods | A state defence customer or a Ukrainian business entity registered with the State Service for Export Control that intends to carry out or carries out international transfers of goods, including brokering. The status is acquired by prior registration (Art. 12). Law No. 549-IV, Arts 1, 12 | “Exporter”, “broker”, “provider of technical assistance” (Regulation 2021/821, Art. 2(3), (8), (10)); “supplier” (Directive 2009/43, Art. 3(3)). The exporter is identified transaction by transaction: the person who holds the contract with the consignee and has the power to determine the sending of the items. | The 2002 Statement on arms brokerage lists registration of brokers among possible measures; the documents do not provide for general registration of exporters. Compendium, p. 29. |
| end-usersкінцеві споживачі · kintsevi spozhyvachi | Ukrainian business entities and state bodies, the Armed Forces and other military formations, law-enforcement bodies and foreign entities that are the direct consumers of goods imported into or exported from Ukraine. Law No. 549-IV, Art. 1 | “End-user” is used in Regulation 2021/821 (for example Arts 2(12)–(13), 12(4)) but is not defined in Art. 2. | End-User Assurances Commonly Used: where goods are exported to a firm that resells them on the local market, that firm is regarded as the end-user (item 1.4). Compendium, p. 85. |
| military end-useвійськове кінцеве використання · viiskove kintseve vykorystannia | Use of any goods for the development, production, assembly, testing, repair, maintenance, modernisation, operation, storage or acquisition of military products, including the use of production and test equipment and of components, the provision of any services, and the incorporation of the goods into such products. Law No. 549-IV, Arts 1, 10 | “Military end-use” means incorporation into military items on a Member State’s military list; use of production, test or analytical equipment for their development, production or maintenance; or use of unfinished products in a plant producing them (Regulation 2021/821, Art. 4(1)(b)). Operation, storage, acquisition and services are not covered. | Use in conjunction with an item on the military list of the Participating State; each state determines its own definition (2003 Statement on non-listed items, footnote). Compendium, p. 57. |
| state export controlдержавний експортний контроль · derzhavnyi eksportnyi kontrol | A set of measures to control international transfers of goods and their use, carried out by the State Service for Export Control and other state bodies. Despite its name, it also covers import, transit, temporary import and export, and end use. Law No. 549-IV, Art. 1 | The regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items (Regulation 2021/821, Art. 1). | “Export controls”, as in the title of the Arrangement (title page of the Lists). |
| internal compliance programme (ICP)система внутрішньофірмового експортного контролю · systema vnutrishnofirmovoho eksportnoho kontroliuIn Ukraine’s OSCE replies: Internal Compliance Program | A set of organisational, legal, informational and other measures taken by the entity to comply with export control legislation. It is mandatory for obtaining powers to export and import military goods and for a general or open permit or conclusion; the State Service for Export Control attests it and issues a certificate (Art. 14). Law No. 549-IV, Arts 1, 14 | “Internal compliance programme (ICP)” (Regulation 2021/821, Art. 2(21)). An exporter using a global export authorisation must implement an ICP unless the competent authority considers it unnecessary (Art. 12(4)); the Regulation does not provide for state attestation. | The 2011 Guidelines (amended 2025) on ICPs: the programmes are not legally binding but are recommended. Compendium, p. 61. |
Documents
| Term · in Ukrainian | Meaning under the Ukrainian Law | EU: term and difference | Wassenaar Arrangement |
|---|---|---|---|
| permitдозвіл · dozvilIn Ukraine’s OSCE replies: permit; together with a conclusion — “license” | A document issued by the State Service for Export Control granting the right to export or import goods. It may be one-off, general or open. Law No. 549-IV, Arts 1, 15 | “Export authorisation” (Regulation 2021/821, Art. 12); “export licence” and “transfer licence” (Directive 2009/43, Art. 3(5)–(6); Common Position 2008/944). The Regulation has no import authorisation for dual-use items. | “Licence” or “authorisation”: both words are used in the compendium without definition. |
| conclusionвисновок · vysnovokIn Ukraine’s OSCE replies: conclusion; together with a permit — “license” | A document issued by the State Service for Export Control granting the right to import or export goods temporarily, to transit them, and to conduct negotiations on contracts for international transfers of military goods or for exports to states under a partial embargo. It is an authorisation, not an expert opinion. Law No. 549-IV, Arts 1, 15 | No separate document. Common Position 2008/944 mentions transit or transhipment licences (Art. 1(2)) and accepts that national procedures may include permission to start negotiations (Art. 4(1)). | The compendium has no counterpart. |
| one-off permit or conclusionразовий дозвіл чи висновок · razovyi dozvil chy vysnovokIn Ukraine’s OSCE replies: single permit/conclusion | Granted for specific negotiations or a specific international transfer to a named end-user, stating the description, quantity and value of the goods. Valid for up to one year; the term may be extended within the term of the contract (Art. 15). Law No. 549-IV, Arts 1, 15 | “Individual export authorisation”: granted to one exporter for one end-user or consignee (Regulation 2021/821, Art. 2(12)); valid for up to two years (Art. 12(3)). “Individual transfer licence” (Directive 2009/43, Art. 7). | The compendium does not define types of licence. |
| general permit or conclusionгенеральний дозвіл чи висновок · heneralnyi dozvil chy vysnovokIn Ukraine’s OSCE replies: general permit/conclusion | Granted to one entity for repeated negotiations or transfers to a named end-user, without stating quantity or value. Valid for up to three years; an internal compliance programme is required (Art. 15). Law No. 549-IV, Arts 1, 15 | Not the same as a “general export authorisation”: in the EU a general authorisation (Union or national) is available to all exporters who meet its conditions (Regulation 2021/821, Art. 2(15)–(16)), and a “general transfer licence” is published for a category of recipients (Directive 2009/43, Art. 5). The Ukrainian general permit is issued on application to one entity. | The compendium does not define types of licence. |
| open permit or conclusionвідкритий дозвіл чи висновок · vidkrytyi dozvil chy vysnovokIn Ukraine’s OSCE replies: open permit/conclusion | Granted to one entity for repeated negotiations or transfers, stating only the description of the goods and the state of destination or origin, for various end-users in that state. Valid for up to three years; an internal compliance programme is required (Art. 15). Law No. 549-IV, Arts 1, 15 | The closest is a “global export authorisation”: granted to one exporter for a type or category of items, for one or more specified end-users and/or third countries (Regulation 2021/821, Art. 2(13)); “global transfer licence” (Directive 2009/43, Art. 6). | The compendium does not define types of licence. |
| guarantee documentдокумент про гарантію · dokument pro harantiiuIn Ukraine’s OSCE replies: guarantee documents | A written undertaking by an authorised state body of Ukraine or of a foreign state that the goods will be used for the declared purposes (an international import certificate, a delivery verification certificate or another document), or a written undertaking by the end-user (an end-user certificate). Law No. 549-IV, Arts 1, 19 | “End-use statement” (Regulation 2021/821, Art. 12(4)); “end-user certificate or appropriate documentation and/or some form of official authorisation issued by the country of final destination” (Common Position 2008/944, Art. 5). | “End-user assurances” (Consolidated Indicative List, as amended in 2022). Compendium, p. 85. |
| international import certificateміжнародний імпортний сертифікат · mizhnarodnyi importnyi sertyfikat | A document issued by an authorised state body of the importing state confirming the importer’s undertaking to import the goods into that state and not to send them elsewhere without that body’s permission. For imports into Ukraine it is issued by the State Service for Export Control (Art. 16); importing under such a certificate extends control to non-listed goods as well (Art. 10). Law No. 549-IV, Arts 1, 10, 16 | Regulation 2021/821 does not use the term. | Neither the Lists nor the compendium uses the term. |
| delivery verification certificateсертифікат підтвердження доставки · sertyfikat pidtverdzhennia dostavky | A document issued by an authorised state body of the importing state confirming that the goods named in it have been delivered to that state. Law No. 549-IV, Art. 1 | Regulation 2021/821 does not use the term. | “Delivery Verification Certificate (DVC)” is an optional element of the assurances: a commitment by the final consignee to provide proof of importation on request (End-User Assurances, item 6.1). Compendium, p. 86. |
| end-user certificateсертифікат кінцевого споживача · sertyfikat kintsevoho spozhyvacha | A document by which the end-user states the place and purpose of end use of the goods and guarantees that they will not be used for other purposes, transferred to another user in the state of destination or re-exported without the permission of the relevant state body. Law No. 549-IV, Art. 1 | “End-user certificate” (Common Position 2008/944, Art. 5); for dual-use items, “end-use statement” (Regulation 2021/821, Art. 12(4)). | “End-user Certificate/Statement”; the essential elements are the parties, the goods, the end-use and an undertaking not to use the goods for other purposes (End-User Assurances, items 1–3). Compendium, pp. 85–86. |
Procedures and the authority
| Term · in Ukrainian | Meaning under the Ukrainian Law | EU: term and difference | Wassenaar Arrangement |
|---|---|---|---|
| State Service for Export Control of Ukraine (SSECU)центральний орган виконавчої влади, що реалізує державну політику у сфері державного експортного контролю · tsentralnyi orhan vykonavchoi vlady, shcho realizuie derzhavnu polityku u sferi derzhavnoho eksportnoho kontroliuIn Ukraine’s OSCE replies: State Service of Export Control of Ukraine (SSECU) | This is how the Law refers to the State Service for Export Control of Ukraine; the Cabinet of Ministers procedures call it Derzhexportcontrol. The English name follows the Service’s own website, which also uses the variant “State Service of Export Control”. Law No. 549-IV, Art. 6 | The “competent authority” of a Member State (Regulation 2021/821, Art. 12(2)). | “Domestic export control authorities” (ICP Guidelines, Annex). Compendium, p. 63. |
| control listsсписки товарів, що підлягають державному експортному контролю · spysky tovariv, shcho pidliahaiut derzhavnomu eksportnomu kontroliu | The lists are compiled by the State Service for Export Control and approved by the Cabinet of Ministers. There are two: the list of military goods (annex to Procedure No. 1807) and the Unified List of Dual-Use Goods (annex to Procedure No. 86). Law No. 549-IV, Art. 9 | Annex I to Regulation 2021/821 (Art. 3(1)) and the EU Common Military List (Common Position 2008/944, Art. 12). | The List of Dual-Use Goods and Technologies and Munitions List. |
| export control expert reviewекспертиза в галузі державного експортного контролю · ekspertyza v haluzi derzhavnoho eksportnoho kontroliuIn Ukraine’s OSCE replies: preliminary examination; identification/classification of goods | Carried out by the State Service for Export Control to decide whether a permit, conclusion or international import certificate may be granted, an entity registered or powers conferred. One of its tasks is to determine whether goods fall within the lists (Art. 11); goods are identified on the basis of the preliminary review (Art. 12). Law No. 549-IV, Arts 11, 12 | Article 2 of Regulation 2021/821 has no corresponding term. | The ICP Guidelines call the assignment of an item to a list “classification”. Compendium, p. 65. |
| registration as an entity engaged in international transfers of goodsреєстрація суб’єкта здійснення міжнародних передач товарів · reiestratsiia subiekta zdiisnennia mizhnarodnykh peredach tovariv | Prior registration with the State Service for Export Control, required of anyone intending to carry out international transfers of goods or brokering. It ends with a registration certificate; applications are considered within 30 working days, or up to 60 where inter-agency approval is needed. Law No. 549-IV, Art. 12 | Regulation 2021/821 does not require general prior registration of exporters. Directive 2009/43 allows Member States to require registration before first use of a general transfer licence (Art. 5(4)). | Registration of brokers is among the possible measures under the 2002 Statement. Compendium, p. 29. |
| powers to export and import military goodsповноваження на право здійснення експорту, імпорту товарів військового призначення · povnovazhennia na pravo zdiisnennia eksportu, importu tovariv viiskovoho pryznachenniaIn Ukraine’s OSCE replies: authorization from the Cabinet of Ministers of Ukraine | A separate clearance granted by the Cabinet of Ministers: without it a business entity cannot export or import military goods or goods containing state secrets. A permit from the State Service for Export Control for the specific transfer is required in addition. Law No. 549-IV, Art. 13 | Common Position 2008/944 and Directive 2009/43 have no counterpart. | The compendium has no counterpart. |
What the Ukrainian Law does not have
EU and Wassenaar terms with no Ukrainian counterpart.
- Intangible transfer of technology: the Law has no term of its own; the closest is “disclosure of technology to a foreigner or stateless person” in the definition of export (Art. 1). The 2006 Wassenaar Best Practices recommend defining such transfers in national law (compendium, p. 13).
- Union general export authorisation and national general export authorisation (Art. 2(15)–(16)): authorisations open to any exporter who meets the conditions; all three kinds of Ukrainian permit are issued on application to a specific entity.
- Large project authorisation (Art. 2(14)): an authorisation for a large-scale project, valid for up to four years (Art. 12(3)).
- Cyber-surveillance items (Art. 2(20)): items for the covert surveillance of natural persons; Law No. 549-IV has no such category.
- Transfer within the meaning of Directive 2009/43/EC (Art. 3(2)): a movement of a defence-related product between Member States; the Ukrainian “international transfers” are much wider.
- Control of non-listed items (catch-all): Ukraine has the mechanism (Art. 10 of the Law), but the Law gives it no name of its own.
How we can help
We help Ukrainian and foreign companies determine whether a transaction falls under state export control, which document it needs and how to describe this in a contract in two languages. See our Dual-Use Technologies and Export Control practice.
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Related materials
This page is not legal advice. Information as of 6 November 2026; sources are Law of Ukraine No. 549-IV and Cabinet of Ministers Procedures No. 86 and No. 1807 as published by the Verkhovna Rada, Regulation (EU) 2021/821, Common Positions 2008/944/CFSP and 2003/468/CFSP, Directive 2009/43/EC, the 2025 Wassenaar Arrangement Lists and its compendium of best-practice documents (December 2025), and Ukraine’s replies to the OSCE questionnaire (FSC.EMI/286/24).