The governments of Russia and Ukraine, the two main Black Sea wheat exporters, seem to have some difficulty grasping the concept of truly open grain markets.

After imposing prohibitive export taxes, licensing requirements or outright export bans in three of the last five years, their leaders have promised this year they will not impose export curbs. Numerous press stories give them credit for exercising “restraint” in avoiding their market meddling tendencies in spite of a drought that reduced their wheat production to below that of 2010.

Russia banned grain exports that year and Ukraine stopped exports with licensing requirements. On the surface, their current stances look more enlightened. But, let us take a closer look at how the market has reacted this year to the slightly more subtle signals Ukrainian and Russian leaders have sent.

Ukraine's government has announced it expects to export 4.0 MMT of wheat in 2012/13 and major Ukrainian exporters have agreed with the Agriculture Ministry not to exceed that limit. One has to assume that if the limit ever does get exceeded, the government would step in to enforce it. What is the difference between an export embargo and the threat of one if the limit is not voluntarily kept? From a practical standpoint, there is no difference at all.

Russia has been less obviously inconsistent with both the Deputy Prime Minister and the Agriculture Minister proclaiming for months that the government will not need to impose an export embargo.

The Minister of the Economy, however, recently said that export curbs are still “quite possible.”

The Institute for Agricultural Market Studies (IKAR) currently estimates Russian wheat exports at 9.5 MMT this year, and even as they proclaimed that restraints would not be needed, their leaders carefully reserved the right to change their minds if grain exports should exceed projections.

While the threat of export restrictions has not been as explicit as in Ukraine, the message to the exporters in both countries was loud and clear. Sell more than the government thinks you should export, or contract for more than a couple of months ahead, and you just might not be able to deliver. Buyers, too, must take that risk into account.