Customs Clearance for Goods Imported into Ukraine
Importing goods into Ukraine requires customs clearance before goods can enter free circulation. The process covers filing a customs declaration, verifying tariff classification and customs value, and paying import duty, VAT and, where applicable, excise. Goods of Ukrainian or EU origin may qualify for zero or reduced duty, provided valid proof of origin is presented.
This article is intended for foreign suppliers, importers, finance and legal teams planning to import goods into Ukraine or assess customs risks before the first shipment.
1. Legal Basis of Customs Clearance
2. Customs Regimes for Importing Goods
3. Declarant and Customs Broker
4. Customs Clearance Procedure
5. Customs Value of Goods
6. Classification and Import Duty
7. Preferential Rates and Proof of Origin
8. Customs Payments on Import
9. Non-Tariff Measures and Permits
10. Sanctions and Restricted Goods
11. Wartime Import Exemptions
12. Typical Importer Mistakes
Frequently asked questions
How DLF Can Help
1. Legal Basis of Customs Clearance
Ukraine’s Customs Code defines customs clearance as “the performance of customs formalities required for the release of goods.” These formalities include filing the customs declaration, document verification, determination of customs value and tariff classification, payment of customs charges, and — where applicable — physical inspection. Release is the customs authority’s act of granting the importer the right to use or dispose of the goods in accordance with the declared purpose.
The person filing the customs declaration is the declarant — an enterprise or individual entrepreneur acting in its or their own name, or an authorised customs broker. A customs broker is not mandatory: the declarant may file the declaration and complete the customs formalities independently without engaging an intermediary.
2. Customs Regimes for Importing Goods
Not every import transaction results in permanent entry into Ukraine’s domestic market. The Customs Code provides several regimes suited to different commercial purposes:
| Regime | Typical use case | Key condition |
|---|---|---|
| Import for free circulation | Standard commercial import for sale or use in Ukraine | All applicable duties and taxes paid before release |
| Temporary import | Equipment, samples, or exhibition items brought for a limited period | Financial security required; goods must be re-exported |
| Customs warehouse | Goods held duty-suspended pending resale or re-export | Customs warehouse subject to the applicable authorization and storage rules |
| Inward processing | Import of materials for manufacturing, processed goods re-exported | Duty suspended during processing; conditions must be met |
| Transit | Goods crossing Ukraine’s territory to a foreign destination | Customs control throughout the transit route |
Choosing an incorrect regime may result in additional duty assessments and penalties.
3. Declarant and Customs Broker
A customs declaration is a standardised statement in which the declarant specifies the customs regime, the description and quantity of the goods, their customs value, and the code under the Ukrainian Classification of Goods for Foreign Economic Activity (UCGFEA). The declaration must be filed within the period established by the Customs Code for the relevant situation. If the goods are not placed under a customs regime or temporary storage in due time, the rules on storage under customs control may apply.
The declarant — whether acting directly or through a broker — bears legal responsibility for the accuracy and completeness of the declaration and all supporting documents. In practice, foreign companies importing goods into Ukraine for the first time generally engage a customs broker because of the complexity of tariff classification and documentary requirements.
4. Customs Clearance Procedure
The Customs Code requires customs clearance to be completed as soon as possible, but no later than four working hours from the moment the goods and commercial vehicles subject to customs clearance are presented to the customs authority, the customs declaration or a document replacing it under law is submitted, and all required documents and information are provided. This period may be exceeded when: the authority requests additional documents to verify customs value or classification; samples are taken for analysis; a potential customs violation is identified; market surveillance measures apply; or authorization of a specific regime is pending. Depending on the grounds of the dispute and the applicable procedure, release against financial security may be available.
The practical sequence for a standard import to free circulation runs:
- Pre-shipment — confirm the correct ten-digit UCGFEA code, identify the applicable duty rate, secure origin proof if preferential treatment is claimed, obtain any required non-tariff permits.
- Arrival — present goods at the designated customs point with transport documents.
- Declaration filing — file within the statutory period; delay may trigger the rules on storage of goods under customs control.
- Review — the authority verifies documents, customs value, tariff classification, and origin.
- Payment — import duty, VAT, and excise (where applicable) are paid before release.
- Release — customs authority grants the right to use and dispose of the goods.
Post-clearance audit remains available to the authority; full commercial records should be retained.
5. Customs Value of Goods
Customs value is not automatically the invoice price. Ukraine’s Customs Code sets out a six-method hierarchy for valuation, each method applied only when the previous cannot be used:
- Transaction value — the price actually paid between buyer and seller; the primary method in the large majority of cases.
- Identical goods — the price at which identical goods were sold for export to Ukraine at the same commercial level.
- Similar goods — the price of functionally equivalent, broadly interchangeable goods.
- Deductive value — derived from the domestic resale price in Ukraine, minus post-import costs.
- Computed value — manufacturing cost plus profit and general expenses in the country of production.
- Fallback — any reasonable approach consistent with WTO customs valuation principles.
At the declarant’s express request, methods four and five may be applied in reverse order. The authority may request additional evidence — original contracts, bank payment records, freight and insurance documents — before accepting the declared value. Where the authority adjusts the value upward, the declarant may challenge the decision by administrative appeal or in administrative court.
6. Classification and Import Duty
The applicable duty rate in Ukraine depends on the goods’ ten-digit UCGFEA code, structured on the World Customs Organization Harmonized System. Under the Law on Customs Tariff of Ukraine, duty rates may be established or amended exclusively by law, not by executive order. The current tariff schedule has been in force since 1 January 2023.
The customs authority verifies the declared code and may reclassify goods where the legal grounds are met. Misclassification results in duty underpayment, potential penalties, and possible re-examination of related prior shipments. For machinery, electronics, chemicals, and composite materials — product categories where classification is commonly contested — confirming the correct code before the first shipment is a practical compliance priority.
7. Preferential Rates and Proof of Origin
The EU-Ukraine Association Agreement and Deep and Comprehensive Free Trade Area (DCFTA) entered into force in its upgraded form on 29 October 2025. Under the agreement, the EU has eliminated 98.1% of all tariff lines for goods of Ukrainian origin; reciprocal preferential rates apply to goods of EU origin entering Ukraine.
Preferential rates do not apply automatically. The importer must present valid origin proof at clearance. The agreement framework recognizes three forms:
- EUR.1 movement certificate — issued by the customs authority of the exporting country; valid for four months; required for consignments with a total invoice value above €6,000, unless the exporter holds REX status.
- Invoice origin declaration — a written statement on the commercial invoice; accepted for consignments of €6,000 or less.
- Registered Exporter (REX) statement — holders of REX registration may declare origin on commercial documents for consignments of any value.
A shipment from an EU member state does not automatically confer EU origin. Goods must satisfy the product-specific rules of origin set out in the DCFTA’s origin protocol. Re-exports or goods with insufficient processing in the EU do not qualify. Without valid origin documentation, the full most-favoured-nation (MFN) duty rate is applied at clearance.
8. Customs Payments on Import
Three categories of payment arise on import for free circulation.
Customs duty is calculated at the rate for the declared tariff code — zero under the DCFTA where valid EU origin is proved, or the MFN rate otherwise.
Import VAT is charged on the import of goods into Ukraine’s customs territory. The VAT base is the contract value of the goods — but not below customs value — plus customs duty and excise where applicable. The amount is converted to hryvnias at the National Bank of Ukraine exchange rate at the date of clearance. The standard rate is 20%.
Excise applies to imports of alcohol products, tobacco, fuel and petroleum products, electrical energy, and certain motor vehicles. All three payments are due before or at release.
Related article: Taxes for German Companies in Ukraine
9. Non-Tariff Measures and Permits
Customs clearance is a necessary but not always sufficient condition for import. Depending on the goods, additional authorizations must be in place before or at the point of clearance:
Veterinary and sanitary control — live animals, reproductive material, veterinary preparations, feed and feed additives, and animal products (meat, poultry, dairy, eggs, fish, honey) may be imported only with a valid veterinary certificate issued by the competent authority of the exporting country.
Phytosanitary control — plants and plant products, seeds, and packaging that may harbour regulated pests require a phytosanitary certificate from the exporting country.
Product licences and permits — pharmaceuticals, pesticides, industrial chemicals, radio-transmitting equipment, and certain other goods require permits from the competent Ukrainian authorities. The specific requirements are determined by the UCGFEA code.
Ukraine’s Single Window system provides for electronic data exchange between customs and other control bodies — veterinary, phytosanitary, and standardisation authorities — reducing duplication of document flows.
10. Sanctions and Restricted Goods
Ukraine’s Law on Sanctions defines sanctions as “special economic and other restrictive measures” adopted by the National Security and Defense Council and enacted by the relevant Presidential decree. Trade sanctions restricting imports include bans on trade operations with certain countries or entities, transit restrictions, and bans on participation in public procurement.
Before each foreign trade transaction, the importer and its legal advisers should verify whether the goods are subject to current prohibitions and restrictions established by the relevant decisions of the National Security and Defense Council (NSDC); whether the counterparty is subject to sanctions; and whether the goods originate from countries subject to relevant prohibitions or restrictions in Ukraine. Sanctions lists are regularly updated and should therefore be checked immediately before the transaction.
Additional export-control requirements may apply to dual-use goods, including the need to obtain the relevant licences or other documents in the exporting country and to comply with the applicable Ukrainian control procedures when importing such goods.
11. Wartime Import Exemptions
Ukraine’s wartime legislation has introduced targeted — not universal — import exemptions. Two remain in force as of the article’s research date.
Duty exemption for specified defence goods may apply to goods and enterprises that meet the statutory criteria. The eligible goods, authorised-enterprise list, reporting obligations and duration of the relief can change and should be checked immediately before import.
VAT exemption for defence entities is also targeted and does not automatically apply to ordinary commercial importers. Eligibility depends on the recipient, the intended use of the goods and the current Tax Code provisions.
Earlier temporary relief for the energy and demining sectors should not be relied on without checking whether the relevant rules have expired, been extended or replaced. There is no blanket wartime duty or VAT exemption for standard commercial imports.
12. Typical Importer Mistakes
Foreign companies importing goods into Ukraine for the first time most often face the following mistakes:
- Declaring an incorrect UCGFEA code → reclassification, additional assessments, and penalties.
- Missing a EUR.1 certificate, invoice origin declaration, or REX status → loss of the preferential rate and application of the full MFN duty.
- Assuming that customs value always equals the invoice price → additional assessments following a customs value adjustment.
- Ignoring veterinary or phytosanitary certificate requirements → goods may be blocked at customs.
- Using temporary exemptions in commercial planning without confirming that they remain in force.
- Conducting sanctions screening only once at contract signing — without repeating it for each shipment.
Frequently asked questions
How long does customs clearance take in Ukraine?
The Customs Code requires customs clearance to be completed as soon as possible, but no later than four working hours from the presentation of the goods and commercial vehicles subject to customs clearance, submission of the customs declaration or a document replacing it under law, and provision of all required documents and information. In practice, clearance may take longer if the customs authority requests additional documents to verify value, takes samples for analysis, identifies signs of a violation, or the procedure for the relevant regime is still being agreed. An incomplete documentation package is a common cause of delay.
Who is responsible for filing the customs declaration?
The customs declaration may be filed by the importer directly (acting as declarant in its own name) or by a customs broker under a power of attorney. A customs broker is optional under Ukrainian law. The declarant — whether the importer or its broker — bears legal responsibility for the accuracy and completeness of the declaration and all supporting documents.
How is customs value determined if the authority disputes the invoice price?
The Customs Code establishes a six-method hierarchy for determining customs value. If the authority considers the invoice price unreliable — for example, because the parties are related or the price differs significantly from market prices — it may proceed to the next method. To defend the declared value, the declarant should retain a complete commercial file: the contract, payment documents, and freight and insurance documents.
What taxes apply to goods imported into Ukraine?
Three payments arise on import for free circulation: customs duty (at the rate for the declared tariff code, potentially zero under the DCFTA for EU-origin goods); import VAT at the standard rate of 20% on the combined base of customs value plus duty plus excise; and excise duty for alcohol, tobacco, fuel, electrical energy, and certain vehicles. All three are payable before or at release.
Do preferential duty rates under the EU-Ukraine agreement apply automatically?
Preferential rates under the DCFTA do not apply automatically. The importer must present valid proof of origin at the time of clearance: a EUR.1 movement certificate for consignments above €6,000, an invoice origin declaration for consignments at or below €6,000, or a Registered Exporter (REX) statement for registered exporters regardless of value. Goods shipped from an EU country but not meeting the DCFTA rules of origin do not qualify for the preferential rate.
Are there customs duty or VAT exemptions for commercial importers during martial law?
Standard commercial importers cannot rely on a general exemption from customs duty or VAT. Targeted exemptions depend on the goods, the recipient, and the current legislation and should therefore be confirmed before each transaction.
How DLF Can Help
DLF attorneys-at-law supports foreign companies and their Ukrainian entities with the legal aspects of importing goods into Ukraine. The work may include reviewing the contractual model, tariff classification, customs value, origin documentation, sanctions exposure and product-specific permit requirements. The firm also advises on contract law and tax law and represents clients in litigation and dispute resolution involving customs authorities, including administrative appeals and court proceedings.
Igor Dronov, Counsel — DLF attorneys-at-law
Contacts: +380 44 384 24 54, info@dlf.ua
This material is intended for general information only. The application of the approaches described above depends on the circumstances of each specific case and requires a separate legal assessment.