On 18 September the Russian government opened a duty-free export route for sunflower oil produced in the occupied Zaporizhzhia region: a tariff quota of 6,000 tonnes, with an export duty of 0 inside it, running to 31 December 2026. The quota is allocated by the region's highest official, the person acting in that capacity, or a deputy they authorise.

Decree No. 1190 is a scan; we read all eight pages, including both annexes. The number that matters is not 6,000 on its own. It is 6,000 compared with 25,000 — the quota the same region had for the same product last year — and with the fact that this route was absent from the annual act for the first 260 days of 2026.

What the decree establishes

“1. To establish, for the period from the day this decree enters into force to 31 December 2026, a tariff quota on the export outside the territory of the Russian Federation to states that are not members of the Eurasian Economic Union of sunflower oil <…>, produced on the territory of the Zaporizhzhia region, placed under the customs procedure of export <…>, in the volume of 6000 tonnes.”

Annex 1 sets the rate inside the quota at 0 roubles per tonne across all five customs codes. Outside the quota, the same annex leaves the ordinary floating rate in force — the one set by decree No. 546 of 6 April 2021. Point 9 puts the decree in force on the day of publication, which was 18 September.

Using the quota requires a one-off export licence from the industry ministry, and the licence requires a prior decision from the region.

The channel was missing from this year's act

Quotas for the occupied territories are normally set once a year, for the calendar year. We read both of the relevant annual acts in full.

Decree No. 2106 of 23 December 2025, the act for 2026, covers only grain: wheat and meslin, barley and maize, for the Donetsk and Luhansk republics and the Zaporizhzhia and Kherson regions. Sunflower oil appears nowhere in it — not in the title, not in point 1, not in annex 1, which is a single row of grain volumes. Zaporizhzhia's figure in that row is 500,000 tonnes.

Decree No. 1900 of 26 December 2024, the act for 2025, is wider. Its annex 1 has three rows, and on two of them every column is a dash except one:

So the oil and meal quotas applied only to Zaporizhzhia, and both were dropped when the 2026 act was written. Nine months later the oil quota returned in a separate decree; the meal quota did not.

The arithmetic

Volume. 6,000 tonnes is 24 per cent of the 25,000 tonnes the region held in 2025.

Time. The 2025 quota ran the full calendar year. This one runs from 18 September to 31 December — 105 days, or 29 per cent of a year. The 260 days from 1 January to 17 September had no oil quota in the annual act.

The grain line changed too. Zaporizhzhia's grain quota went from 1,000,000 tonnes for 2025 to 500,000 tonnes for 2026 — exactly half. That halving is in the annual act and has nothing to do with this week's decree; we note it because it is the same region, the same instrument and the same pair of documents.

We are not putting a rouble figure on the duty foregone. The decree sets the in-quota rate at zero and says nothing about what the rate would otherwise have been; the out-of-quota rate under decree 546 is a variable rate calculated monthly and published by the agriculture ministry, and we did not verify the September figure against a primary source in this session. Six thousand tonnes multiplied by an unverified rate is not a number this site prints. What the documents do establish is the cap: whatever the rate, the duty foregone can apply to no more than 6,000 tonnes.

Who decides who gets it

This is the part of the decree that is not about tonnes. Point 3:

“3. The distribution of the tariff quota is carried out by the highest official of the Zaporizhzhia region (the person acting in that capacity) or a person authorised by them holding a post no lower than deputy chairman of the highest executive body of the Zaporizhzhia region, upon application by participants in foreign trade activity under rules approved by the highest official of the Zaporizhzhia region (the person acting in that capacity) in agreement with the Ministry of Economic Development of the Russian Federation, the Ministry of Agriculture of the Russian Federation and the Ministry of Industry and Trade of the Russian Federation.”

The same authority both writes the rules for allocating the quota and allocates it. The three federal ministries agree the rules; they do not make the decisions. Each decision is issued on the form in annex 2, a copy goes to two of those ministries within one working day, and the decision is the basis for the export licence.

The mechanism is inherited rather than new: decree 2106 gives the same power to the head of each of the four regions for grain, and decree 1900 did the same in 2025. What is specific to decree 1190 is that the power now applies to a route for one region, one product and less than a third of a year.

What this changes in our model

Nothing, and we do not expect that to change. Export duty on sunflower oil is non-oil-and-gas revenue of the federal budget, so any effect would appear in the budget deficit, which scores 65 out of 100 with the rolling twelve-month deficit at 3.3 per cent of GDP. We are not placing the decree on that scale, because doing so would need the rouble figure we have just declined to compute. The narrower thing we can say is that the decree publishes no sum, and nothing in it produces a number this indicator reads.

We are writing it up because of what it shows rather than what it costs: a revenue channel for an occupied region that was closed for most of the year, reopened at a quarter of its previous size for its final months, with the allocation in the hands of one appointee. The strength index stands at 47.3 out of 100, in the stress zone, and no indicator moved today. The live state of all eight is on the monitor.

What we do not know

Why oil and meal were dropped from the 2026 act. Neither decree 2106 nor decree 1190 carries an explanatory note, and we found none published.

Whether anything filled the gap between January and September. We verified that the annual act for 2026 covers grain only, and that decree 1190 starts its own quota on 18 September rather than on 1 January. We did not run an exhaustive search of every government act issued this year, so we are describing the annual act and this decree, not asserting that no other instrument applied to the product in the intervening period.

Whether the 2025 quota was ever used up. We have no data on how much of the 25,000 tonnes was actually exported. A quota is an entitlement, not a shipment, and 24 per cent of an unused entitlement would mean something different from 24 per cent of one that was fully used.

Why the meal did not come back. Sunflower meal had the larger 2025 quota of the two, at 35,000 tonnes. Decree 1190 does not mention it.

Who will receive the licences. The decree sets the form of the decision and the route to the licence. Nothing about the recipients is published, and the rules that will govern the allocation had not been approved when the decree was published.

The September duty rate. The floating rate under decree 546 is the figure that would price this. We did not read the agriculture ministry's own publication of it in this session, which is why no rouble amount appears above.