Import of Components for Weapons Production in Ukraine
Components classified under Ukrainian law as military goods or dual-use goods generally require an import permit from the State Service of Export Control of Ukraine (SSEC of Ukraine). During martial law, specific goods expressly listed by the Cabinet of Ministers are exempt. Before contracting or shipment, the parties should therefore classify the goods, verify the current exemption list and confirm that the Ukrainian importer is properly registered.
This overview is intended for foreign defence manufacturers, component suppliers, investors, legal advisers and export-compliance teams assessing lawful supplies to Ukrainian defence producers.
1. Classification of Controlled Goods
2. Legislative Framework and Regulatory Structure
3. SSEC of Ukraine: Competent Authority and Registration
4. Import Permit Procedure for Military Goods
5. Import Permit Procedure for Dual-Use Goods
6. What Does Not Require a Permit: Martial-Law Exemptions
7. Customs and Tax Treatment
8. Sanctions: Restrictions on Goods with Russian or Belarusian Connections
9. Position of the Foreign Supplier
10. Practical Checklist
Frequently Asked Questions
How DLF Can Help
1. Classification of Controlled Goods
The starting point is the legal classification of the specific product. The Law of Ukraine “On State Control over International Transfers of Military and Dual-Use Goods” No. 549-IV governs military goods, dual-use goods and, where applicable, controlled technologies and services.
Military goods are items specially designed or modified for military use and covered by the relevant list of military goods. Control may also extend to parts and components specially designed for listed items.
Dual-use goods have civilian applications but may be subject to export control because of their technical characteristics. The applicable Ukrainian control list is established under the Cabinet of Ministers procedure governing dual-use goods.
Components that do not fall within the control lists and are not subject to catch-all control do not require an SSEC of Ukraine import permit.
| Category | SSEC of Ukraine permit | Martial-law exemption | Customs/VAT treatment |
|---|---|---|---|
| Military goods | Generally required | Possible only for goods on the current exemption list | Separate assessment |
| Dual-use goods | Generally required | Possible only for goods on the current exemption list | Separate assessment |
| Certain unmanned-system components | Depends on classification and exemption | May apply | Special relief may apply |
| Controlled goods outside an exemption | Required | No | Current rules apply |
| Non-controlled civilian goods | Not required | N/A | Standard regime |
Classification requires a technical and legal assessment. A commercial description or customs code alone does not replace a comparison of the product characteristics against the relevant control lists.
2. Legislative Framework and Regulatory Structure
The principal statute is the Law of Ukraine “On State Control over International Transfers of Military and Dual-Use Goods” No. 549-IV. It establishes the types of international transfers, the powers of SSEC of Ukraine and the core duties of entities carrying out international transfers.
Military goods are governed in detail by Cabinet of Ministers Resolution No. 1807 of 20 November 2003 “On Approval of the Procedure for State Control over International Transfers of Military Goods”. Dual-use goods are governed by Cabinet of Ministers Resolution No. 86 of 28 January 2004 “On Approval of the Procedure for State Control over International Transfers of Dual-Use Goods” and Cabinet of Ministers Resolution No. 875 of 1 July 2026 “Certain Issues of International Transfers of Goods During the Period of Martial Law in Ukraine”.
During martial law, these instruments must be read together with the temporary exemption rules and the special wartime procedure for international transfers.
3. SSEC of Ukraine: Competent Authority and Registration
The State Service of Export Control of Ukraine is the competent Ukrainian authority for state export control and issues permits for international transfers of controlled goods.
Before applying for an import permit, the Ukrainian business entity must complete registration with SSEC of Ukraine as an entity carrying out international transfers of goods.
Depending on the transfer pattern, SSEC of Ukraine may issue single, general and open permits. Additional requirements may apply to general and open permits, including an internal company control system.
For a foreign supplier, the practical issue is to identify the Ukrainian importer early and confirm that it is properly registered and can obtain the required permit in time.
4. Import Permit Procedure for Military Goods
The application package submitted for an import permit depends on the specific transaction. The application may be submitted online via the Diia service. The application may be accompanied by documents confirming the legal basis or intention to carry out the transfer, documents confirming the parties’ compliance with the applicable requirements, information on the value of the goods and other documents required under the applicable procedure.
When planning the supply, the parties should distinguish between the importer’s prior registration with SSEC of Ukraine and the review of the particular import-permit application.
5. Import Permit Procedure for Dual-Use Goods
The underlying rules are established by Cabinet of Ministers Resolution No. 86 of 28 January 2004 “On Approval of the Procedure for State Control over International Transfers of Dual-Use Goods”.
During martial law, the special rules under Resolution No. 875 must also be considered for the relevant transaction. The required document package should be determined under the current procedure for the relevant type of transfer rather than by relying on outdated document lists or formal distinctions in earlier versions of the rules.
In practice, the component should first be classified. Only then can the required permit, supporting documents and applicability of an exemption during martial law be determined.
6. What Does Not Require a Permit: Martial-Law Exemptions
Cabinet of Ministers Resolution No. 1378 of 9 December 2022 creates a specific list of goods whose import is exempt from the permit regime for the duration of martial law. The list has been amended several times.
It includes certain unmanned systems and parts, communications equipment, optical and protective equipment and other expressly listed items. The exemption is not a general waiver for all defence goods: the current list and its exclusions must be checked for every shipment.
Since early July 2026, additional rules have been set out in Cabinet of Ministers Resolution No. 875 of 1 July 2026 “Certain Issues of International Transfers of Goods During the Period of Martial Law in Ukraine”.
The simplified regime during martial law does not apply to all goods. For each import, it is necessary to verify whether the exemption applies to the specific product.
7. Customs and Tax Treatment
An exemption from the SSEC of Ukraine permit requirement and an exemption from customs duties or VAT are separate legal regimes. One does not automatically entail the other.
Import duty. Law of Ukraine No. 3124-IX introduced specific relief that has since been amended. Eligibility must be checked under the current Customs Code by reference to the relevant customs classification, intended use and statutory conditions. There is no blanket duty exemption for all defence components.
VAT for unmanned-system production and repair. Law of Ukraine No. 3123-IX expressly addresses imports of specified goods subject to the statutory conditions.
Other security and defence goods. Law of Ukraine No. 3019-IX provides additional VAT relief for specified categories. The current Tax Code must be checked for the exact goods and conditions.
Related article: Customs Clearance for Goods Imported into Ukraine
8. Sanctions: Restrictions on Goods with Russian or Belarusian Connections
The National Security and Defence Council Decision of 20 November 2023 on sectoral sanctions in the defence-industrial sphere imposes sectoral restrictions for 50 years. The sanctions include restrictions on relevant defence-industrial operations with residents of Russia and Belarus.
Sanctions screening should cover the counterparty, the legal structure of the transaction, the origin of the goods and other relevant links.
Where the connection to a sanctioned jurisdiction is indirect, the result depends on the facts and the sanctions instruments applicable to the particular transaction.
9. Position of the Foreign Supplier
Under Ukrainian law, the Ukrainian importer registers with SSEC of Ukraine and obtains the Ukrainian import permit. The foreign supplier nevertheless contributes to the contractual and compliance documentation and should align end-use and onward-transfer restrictions with the Ukrainian counterparty.
A Ukrainian permit does not replace an export licence required in the supplier’s home jurisdiction. EU suppliers remain subject to the EU dual-use regime and, where relevant, national military-export rules. US and UK suppliers are subject to their respective export-control regimes.
The two sides should therefore coordinate classification, licensing timelines, contractual conditions and end-use documentation before shipment.
10. Practical Checklist
- Check the goods classification against the current Ukrainian control lists.
- Check whether the specific product falls within the current martial-law exemption under Resolution No. 1378.
- Confirm the Ukrainian importer’s registration status with SSEC of Ukraine and allow for the required lead time.
- Determine the applicable permit procedure and currently required documents under Resolution No. 875 and the Diia administrative service.
- Separately check the customs classification, intended use and conditions for any import-duty or VAT relief.
- Screen the counterparty, goods origin and relevant ownership/control relationships for sanctions risks.
- Align home-country export-control obligations and licensing timelines with the Ukrainian procedure.
- Before shipment, recheck the status of martial law, the exemption list and other rules that may change.
Frequently Asked Questions
Does importing electronic components for UAV production always require a SSEC of Ukraine permit?
No. The component must first be classified and then checked against the current wartime exemption list. Customs-duty and VAT relief are separate questions and require their own assessment.
Can a foreign company supply components directly to a Ukrainian private defence manufacturer?
Yes, Ukrainian law does not generally require every such supply to be routed through a state procurement body. The Ukrainian importer must nevertheless comply with the applicable export-control, customs, sanctions and contractual requirements.
Are defence components generally exempt from customs duty?
No. Relief applies only where the specific goods and use meet the conditions in the current Customs Code. The Ukrainian customs classification and the applicable statutory conditions must be checked for the actual shipment.
Must the foreign supplier register with SSEC of Ukraine?
The official registration procedure is framed for a Ukrainian business entity — a legal entity or individual entrepreneur. A foreign supplier should therefore not assume that it can replace the Ukrainian registered importer without specific confirmation from SSEC of Ukraine.
How DLF Can Help
DLF attorneys-at-law supports foreign defence manufacturers, component suppliers and investors at the key stages of entering and operating in Ukraine: product-classification and SSEC of Ukraine documentation, foreign-trade contracts, sanctions screening, customs and tax analysis, and procurement support where relevant. For these projects, DLF’s Contract Law and customs-related services and Public procurement practice are particularly relevant.
Iurii Dynys, Counsel, Attorney-at-law — DLF attorneys-at-law
Contact: +380 44 384 24 54, info@dlf.ua.
This material is intended for general information only. The application of the approaches described depends on the circumstances of the particular case and requires a separate legal assessment.