eAktsyz in Ukraine for Alcohol and Tobacco Importers
Ukraine is introducing eAktsyz. The system tracks the circulation of alcoholic beverages, tobacco products and liquids used in electronic cigarettes. An electronic excise stamp contains a unique identifier and other data from the system. These data make it possible to identify each unit of goods at every stage of its movement.
Mandatory electronic excise marking is scheduled to begin on 1 July 2027.
This article is intended for foreign suppliers, Ukrainian importers and distributors, and their legal, finance and logistics teams. It addresses registration, import marking, consignment documentation and the treatment of stocks bearing paper excise stamps.
1. Businesses Covered by eAktsyz
2. eAktsyz Launch Dates and Legislative Changes
3. Three Phases of the Transition to Electronic Marking
4. eAktsyz Registration Deadlines
5. Marking Imported Goods from 1 July 2027
6. Transitional Rules for Goods with Paper Excise Stamps
7. Penalties and Transitional Reductions
Compliance Checklist for Alcohol and Tobacco Importers
Frequently Asked Questions
How DLF Can Help
1. Businesses Covered by eAktsyz
The Law of Ukraine “On State Regulation of the Production and Circulation of Ethyl Alcohol, Spirit Distillates, Bioethanol, Alcoholic Beverages, Tobacco Products, Tobacco Raw Materials, Liquids Used in Electronic Cigarettes, and Fuel” specifies who must register in eAktsyz. The requirement covers producers, importers, wholesalers and retailers holding the relevant licences.
2. eAktsyz Launch Dates and Legislative Changes
The Law of Ukraine “On Amendments to the Tax Code of Ukraine and Certain Other Laws of Ukraine Concerning the Postponement of the Deadlines for Introducing Electronic Traceability of the Circulation of Alcoholic Beverages, Tobacco Products and Liquids Used in Electronic Cigarettes” set the transitional deadlines. The rules on registration as an economic operator take effect on 1 January 2027.
3. Three Phases of the Transition to Electronic Marking
| Phase | Period | Participation status |
|---|---|---|
| All components operating in test mode | 1 January – 31 December 2026 | Voluntary testing |
| Production system operating in test mode | 1 January – 30 June 2027 | Testing is voluntary; registration is mandatory by the statutory deadlines |
| Mandatory electronic traceability and marking | From 1 July 2027 | Mandatory for operators and products within the statutory scope |
Software testing runs from 1 March 2025 through 30 June 2027. From 1 January 2027, certain functions, including registration of economic operators and the creation of their electronic accounts, will operate in production mode. During testing, businesses must continue to comply with the existing rules on paper excise stamps, excise duty payments and licensing.
4. eAktsyz Registration Deadlines
A business submits a single application to register as an economic operator, even if it holds several licences. The registration deadline depends on when it obtained the relevant licence.
| Licence or Registration Status | Registration Deadline |
|---|---|
| At least one relevant licence valid at 00:00 on 1 January 2027 | Before 1 April 2027 |
| Licence obtained from 1 January to 20 March 2027 inclusive | No later than 1 April 2027 |
| Licence obtained from 21 March 2027 | Before commencing the relevant licensed activity |
| Operator registered between 1 January and 30 June 2027 | No re-registration required from 1 July 2027 |
5. Marking Imported Goods from 1 July 2027
As a general rule, the importer must ensure that the packaging of each unit subject to marking under the Tax Code of Ukraine carries the graphic element of an electronic excise stamp.
Marking format. The code must comply with DataMatrix ECC 200 or its latest equivalent. The first 12 characters of the unique identifier must also appear on the packaging in human-readable form. The marking must leave mandatory packaging information visible. If the graphic element is printed on a physical carrier, the carrier must be attached so that it cannot be removed without damage.
There are two main marking routes:
- Before importation. The graphic element is applied abroad. The importer should agree with the manufacturer how identifiers are transferred and how codes are printed and checked.
- In a customs warehouse. Goods are marked under the customs warehousing procedure before release for free circulation. Special rules apply to certain tobacco products.
Notification after importation. The importer prepares a notification recording the movement of imported marked goods. The notification contains customs declaration data, the facility code or customs-control location details, and a list of unique or group identifiers.
For goods marked before importation, the importer prepares the notification after receiving the goods and scanning the graphic elements or group identifiers at its own facility or a temporary storage warehouse. For goods marked under the customs warehousing procedure, notification follows marking, scanning at the customs warehouse or the importer’s facility, and customs clearance for release for free circulation. An electronic excise document is prepared for subsequent transactions involving marked goods in the cases prescribed by law.
Special tobacco rule. Products under specified customs tariff codes must be marked during manufacture.
Tobacco products from the EU. A special procedure applies to products manufactured in an EU Member State and marked with unique identifiers under the EU tobacco traceability rules. Before the date of importation, the importer submits a notification in eAktsyz containing information on the applied identifiers. This is treated as generating identifiers, and no additional graphic element of a Ukrainian electronic excise stamp is required.
6. Transitional Rules for Goods with Paper Excise Stamps
During the transition, the existing rules on circulation apply to goods bearing paper excise stamps under the conditions set out in the table.
| Situation | Applicable rule |
|---|---|
| Goods manufactured in Ukraine or imported before 1 July 2027 and properly marked with paper excise stamps | May remain in circulation until 31 December 2028 inclusive |
| Goods imported from 1 July 2027 | Electronic marking is required for goods within scope, subject to statutory exemptions |
| Paper-stamped stocks remaining from 1 January 2029 | Withdrawal from circulation for electronic re-marking |
| Stocks re-marked through the statutory procedure | May return to circulation without additional excise duty |
Retain customs declarations and other import records to substantiate the date of importation.
Purchased paper excise stamps that remain unused on 1 July 2027 must be returned to the tax authority that sold them. According to the Ministry of Finance of Ukraine, the return deadline has been extended to 1 January 2028.
A buyer who returns paper excise stamps may choose between a refund of the excise duty paid when purchasing those stamps and a credit for that duty when electronic stamps are generated. Amounts paid under the special rules for taxing alcoholic beverages can only be credited.
To re-mark remaining stock, the owner orders unique identifiers in eAktsyz and applies the graphic elements of the electronic excise stamps to the packaging.
7. Penalties and Transitional Reductions
Reduced fines apply to producing, importing, wholesaling or retailing goods subject to electronic marking without registration as an economic operator. They also apply to dispatching such goods without a required electronic excise document and to receiving and storing them without that document. The law provides exceptions for certain cases of storage.
| Date of violation | Percentage of the statutory fine payable |
|---|---|
| 1 July – 31 December 2027 | 10% |
| 1 January – 30 June 2028 | 30% |
| From 1 July 2028 | 100% |
The fine for carrying out these activities without registration as an economic operator is 100% of the value of the goods concerned. For the electronic excise document offences described above, it is 10% of their value. The percentage in the table is determined by the date of the offence.
Storing, transporting or selling goods deemed to lack electronic excise stamps carries a fine of 200% of their value, but not less than six monthly minimum wages. The minimum fine is calculated using the monthly minimum wage in force on 1 January of the year in which the offence is detected. Exceptions apply, including where goods with damaged graphic elements are stored for return to the manufacturer or importer or transported in the course of that return. The transitional reduction does not apply to this fine.
Compliance Checklist for Alcohol and Tobacco Importers
By 31 December 2026
- Test eAktsyz in the Sandbox and assess the need for integration with accounting and warehouse software.
- Review existing and planned licences, identify the relevant registration deadlines and assign responsible staff.
Registration within the Applicable Deadlines
- Check the details of current licences and facilities before registering.
- Register as an economic operator within the deadline applicable to the date the licence was obtained.
By 1 July 2027
- Choose the marking route for each commodity code and agree printing, quality checks and corrections with the supplier.
- Budget for excise duty, printing the required markings and technical integration.
- Draw up an inventory of unused paper excise stamps and prepare the documents needed to claim an excise duty credit or refund.
- Train staff to prepare import notifications and electronic excise documents.
From 1 July 2027
- Prepare notifications on imported goods after receipt and scanning; prepare electronic excise documents for subsequent transactions where the law requires them.
- Keep evidence that consignments bearing paper excise stamps were imported before 1 July 2027. Plan the sale or re-marking of remaining stocks.
- Bear in mind that reduced fines are available until 30 June 2028 and do not cover the circulation of goods deemed unmarked.
Frequently Asked Questions
When will electronic excise marking become mandatory?
From 1 July 2027. The existing rules on paper excise stamps apply until then.
When must economic operators register in eAktsyz?
Holders of licences valid at the start of 1 January 2027 must register before 1 April. For licences obtained from 1 January to 20 March 2027 inclusive, the registration deadline is 1 April. For licences obtained from 21 March 2027, registration is required before starting the relevant activity.
Can goods with paper excise stamps continue to circulate after 1 July 2027?
Goods manufactured in Ukraine or imported before 1 July 2027 and properly marked with paper excise stamps may remain in circulation until 31 December 2028 inclusive. From 1 January 2029, remaining stocks must be withdrawn for re-marking. Once re-marked, they can return to circulation without additional excise duty.
How are imported goods marked in practice?
As a general rule, goods are marked abroad before importation or under the customs warehousing procedure before release for free circulation. The marking section above explains the special rules for certain tobacco products.
What fine applies to unmarked goods?
Storing, transporting or selling goods deemed to lack electronic excise stamps carries a fine of 200% of their value, but not less than six monthly minimum wages. The transitional reduction does not apply to this fine. Statutory exceptions apply.
Where are registration and technical guidance available?
Register through the electronic account at my.xtrace.gov.ua. Instructions and testing materials are available at xtrace.gov.ua.
How DLF Can Help
DLF attorneys-at-law supports foreign companies and investors entering Ukraine’s excisable-goods market, from corporate structuring and licensing analysis to the preparation of eAktsyz registration documents. Its lawyers review tax and customs requirements, prepare supply contracts allocating marking duties and liability, and advise on the transition from paper to electronic excise stamps.
Igor Dykunskyy, LL.M., Attorney-at-law, Partner, DLF attorneys-at-law.
Contact: +380 44 384 24 54, info@dlf.ua.
This material is intended for general information. The application of these rules depends on the circumstances of each particular situation and requires a separate legal assessment.