There are currently purpose-specific customs control procedures for importing goods to Ukraine during wartime:
- For humanitarian aid (CMU Resolution No. 174 dated March 1, 2022), the import of goods is carried out according to the declarative principle and/or based on the submission to the customs authorities of a guaranteed letter of the end user of the goods in the established form using a simplified customs clearance procedure.
- For specified goods imported into Ukraine during the period of martial law, in accordance with Resolution of the CMU No. 236 of March 9, 2022, which allows for a deferral of customs payments. Such goods include medicines, medical products and medical products, food products according to the established groups of goods, military goods, according to the list determined by Resolution of the CMU No. 1807 of November 20, 2003, and goods of critical import according to the list of Resolution of the CMU No. 153 from February 24, 2022. Other goods are subject to customs control and registration to the extent determined by the Customs Code of Ukraine.
The most recent Resolution of the Cabinet of Ministers, dated October 10, 2020, introduced new procedures for interaction between declarants and customs authorities regarding the movement of goods and vehicles across the customs border of Ukraine using the “single window” mechanism. According to these procedures, interactions between declarants and customs authorities are electronically recorded during the official control and preliminary documentary customs control measures. The record contains information from companies, regulatory authorities, customs authorities, and the automated customs clearance system. It also includes documents and information used for official control measures and preliminary documentary control, information about the regulatory and customs authorities who carry out official control measures, and preliminary documentary control.
Despite some procedural improvements made by Ukraine, U.S. companies exporting goods to Ukraine should continue to expect onerous bureaucratic procedures and paperwork when dealing with Ukraine’s State Customs Service. As a result, many firms choose to use customs brokers to navigate through the often changing and seemingly inconsistent customs clearance process. For a list of customs brokers, contact the Association of Customs Brokers of Ukraine.
The Ukrainian Classification of Goods of Foreign Economic Activity was compiled based on the harmonized system and the Combined Nomenclature of the European Union and its text in the original language prevail over the text translated into Ukrainian. Depending on the code of goods in the Ukrainian Classification of Goods of Foreign Economic Activity, some products may require prior approval, be subject to sanitary and epidemiological control, veterinary control, phytosanitary or environmental control, or may be prohibited altogether. The complete list of products with respective import restrictions is available on Ukraine’s State Customs website (://customs.gov.ua/httpsen/).
Import licenses that require prior approval from a relevant administrative agency are issued by the Ministry of Economy subject to the Resolution of the Cabinet of Ministers of Ukraine.
In 2016, Ukraine established the State Service of Ukraine on Food Safety and Consumer Protection (SSUFSCP). The SSUFSCP has the authority of the State Veterinary and Phytosanitary Service of Ukraine, the State Inspection of Ukraine for Protection of Consumers’ Rights, as well as the functions of state control over compliance in the following areas: tourism and resorts; consumer rights protection regarding goods of precious metals and gemstones; and compliance of the rights to plant varieties in seed and plant production by legal entities.
Every year the GOU composes the list of products subject to import and export licensing. The current list of products can be found in the Regulation of the Cabinet of Ministers of Ukraine No. 1402 “On Approval of the List of Products subject to Import and Export Licensing and Respective Quotas for 2026,” dated December 31, 2025. In 2025, the list included: salt, natural gas, coal, wood, silver, gold, waste and scarp of precious metals, wheat and other grains, vegetable oils, sugar, pharmaceuticals, paints and lacquers, dyes, hygiene products, cosmetic products, pedicure and manicure products, shaving aerosols and deodorants, lubricants, waxes, shoe polishes, insecticides, solvents, silicone, fire extinguishers and the chemicals that fill extinguishers, refrigerators and freezers, air-conditioners, humidifiers, and other selected industrial chemical products, fungicides, herbicides, and plant growth adjusters and other products.
Regulation of export flows in some cases is delegated to an importing country or a group of countries. The majority of export flows to the EU (like poultry or red meat) are regulated by the EC on a first-come, first-served basis. Most import licenses are granted through the Ministry of Economy, Regional and Kyiv City Administrations.
Other import licenses or approvals are issued by other agencies such as the Ministry of Internal Affairs, the State Service of Ukraine on Medicines and Drug Control, or the Ministry of Ecology and Natural Resources. A listing of Ukrainian agencies that issue licenses for business activities in Ukraine is available at the Parliament of Ukraine’s website (rada.gov.ua)
Customs clearance is conducted in designated customs clearance locations. The main document required for customs clearance is a customs declaration completed by an importer of record (or by a customs broker acting on their behalf).
In August 2022, the Parliament of Ukraine approved the law on customs “visa-free regime” with the EU. This law provides for the accession of Ukraine to the Convention on the Common Transit Procedure and the New Computerized Transit System (NCTS). The changes provide for the introduction of a European complaint handling mechanism and the continuation of the digitalization of customs, which will speed up its passage and reduce corruption risks.
A Certificate of Origin is required when preferential customs duty rates are applied, when certain quantitative restrictions on movement of goods across the customs border of Ukraine are applied, and if Ukrainian law or international treaties declare it so.
According to Article 49 of the Customs Code, the customs value of goods is defined as the cost of goods used for customs purposes, based on the price actually paid or to be paid for the goods, which usually includes the cost of goods, insurance cost, and transportation cost. Other costs under certain conditions may be included in the customs value of goods, such as royalties or license fees. The Customs Code establishes one main and several secondary methods of determining the customs value of imported goods. The basic method of determining the customs value of goods imported into Ukraine according to Article 57 is the price of the contract (the transaction value of the imported goods). The Customs Code requires an exhaustive list of documents to be submitted to determine the custom value of goods.
The list of required documents to be presented to customs authorities changes frequently, and under the Customs Code, the importer of record may be required to submit additional documents specified by the applicable legislation. Therefore, American exporters are advised to vest customs clearance in Ukraine as contract liabilities of the Ukrainian trading partner or end-user customer. For a list of customs brokers contact the Association of Customs Brokers of Ukraine and the website of the State Fiscal Service.