Introduction of Duty on Natural Stone May Lead to Quarry Shutdowns — Risks for the Industry
The introduction of an export duty on natural stone may affect the operation of mining enterprises, market competition conditions, and Ukraine's fulfillment of international obligations. The National Association of Advocates believes that the new provision requires additional legal assessment, and businesses should already consider possible mechanisms to protect their interests.
How the New Duty Was Introduced
On June 9, 2026, Law No. 4903-IX "On Amendments to the Tax Code of Ukraine and Other Legislative Acts of Ukraine Regarding the Implementation of International Automatic Exchange of Information on Income Received through Digital Platforms and Taxation of Such Income" was adopted.
During the preparation of bill No. 15111-d before the second reading, a provision introducing an export duty on natural stone was included in the document. The duty rate was set at 0.3 euros per kilogram.
The NAAU noted that the provision on export duty is not related in substance to the regulation of digital platforms. Therefore, according to lawyers, questions arise regarding compliance with the Verkhovna Rada's regulations, proper public discussion, and regulatory impact analysis.
Risks Seen for the Mining Industry
The National Association of Advocates of Ukraine points out that introducing a fixed duty rate without a sufficient transition period may create unequal conditions for enterprises engaged in natural stone extraction that do not have the technical or economic capacity to quickly switch to processing it.
According to lawyers, for some quarries, suspension of activities may lead to the loss of production teams, disruption of technological processes, and reduction of tax revenues to local budgets. This especially concerns communities where such enterprises are important employers and sources of budget revenues.
Appeal to the Antimonopoly Committee and Other Steps
One possible response tool named by the NAAU is an appeal to the Antimonopoly Committee of Ukraine. This step may be necessary to check whether the new regulation creates non-competitive conditions or advantages for certain participants in the natural stone processing market.
Additionally, lawyers proposed a phased roadmap to protect the interests of subsoil users.
The first stage may be an appeal to the President of Ukraine requesting consideration of procedural and international legal reservations when deciding on signing the law.
The second stage involves creating a working group with the participation of the Cabinet of Ministers, relevant authorities, industry representatives, and the legal community. Its task may be to prepare legislative amendments providing a real transition period, a separate regime for already concluded foreign economic contracts, and phased introduction of duty rates.
Judicial and International Protection Mechanisms
The NAAU also points to the possibility of using judicial and international protection mechanisms.
Possible steps include preparing a constitutional submission, appealing decisions and actions of customs authorities in administrative courts, and addressing European Union institutions to assess the compatibility of the new duty with the provisions of the Association Agreement between Ukraine and the EU.
The National Association of Advocates of Ukraine declared its readiness to provide expert and legal support to subsoil users to protect their rights and legitimate interests.
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