Ukrainian defense manufacturers are still encountering a difficult route to overseas sales months after Kyiv introduced a special export regime for military and dual-use products, according to company representatives interviewed by Breaking Defense at the AUSA conference and in Lviv.
The reported constraint matters for procurement partners seeking Ukrainian unmanned-system and defense-technology suppliers: the framework creates a potential legal channel, but it does not establish unrestricted exports. A Phantom Defense spokesperson told Breaking Defense that there remains “a significant gap between the formal procedure and its practical implementation,” describing licensing as a potential bottleneck. Oko Camera co-founder Denys Nikolayenko said firms classified as dual-use suppliers can export more readily than companies producing only defense products.
The regime is built around Cabinet of Ministers Resolution No. 875, which entered into force on July 8 and applies to military and dual-use goods. Under the Impact Law analysis of the resolution, exports require a licence from the State Service for Export Control, with Ministry of Defence approval and interagency clearance required within a review period of no more than 30 calendar days.
The rules also limit the route’s scope. As a general rule, exports are permitted to states participating in the Drone Deal format, while a list of goods whose export could threaten Ukraine’s defense capability is being developed. Finished-product shipments must be valued at at least UAH 15 million to qualify for a licence; components and spare parts are not subject to that threshold, according to the legal analysis.
Companies are therefore pursuing alternatives alongside conventional licensing, Breaking Defense reported. Those include foreign industrial partnerships, localized production arrangements and foreign-government procurement of Ukrainian systems under the Danish model. A Phantom Defense representative said unspecified analytical studies identified more than 180 international partnerships in Ukraine’s defense industry, and that more than 20 percent were still at the memorandum-of-understanding stage rather than practical implementation.
These accounts are industry assessments rather than evidence of completed export contracts. They indicate that the new regime has created an export mechanism but that manufacturers still face approval, partner-country and product-eligibility constraints before it can support routine foreign sales.