From 1 December 2024, an export licensing regime will be introduced for the export of certain types of goods (in accordance with Resolution No. 1261 of the Cabinet of Ministers of Ukraine dated 29 October 2024). In particular, this applies to goods classified under the following codes in accordance with the Ukrainian Classification of Goods for Foreign Economic Activity (UKT ZED):

0409 00 00 00 – natural honey;

0802 31 00 00 – walnuts in shell;

0802 32 00 00 – walnuts, shelled;

1001 – wheat and a mixture of wheat and rye (meslin);

1002 – rye;

1003 – barley;

1004 – oats;

1005 – maize;

1201 – soya beans;

1205 – rapeseed or colza;

1206 00 – sunflower seeds;

1507 – soya oil and its fractions, whether or not refined;

1512 – sunflower, safflower or cotton seed oil and their fractions, whether or not refined;

1514 – rapeseed (from rapeseed or colza) or mustard oil and their fractions, whether or not refined;

2306 – oilcake and other solid waste and residues resulting from the extraction of vegetable or microbial fats and oils, excluding waste of heading 2304 or 2305 (hereinafter referred to as ‘specific types of goods’).

At the same time, exceptions are provided for in the list of specific types of goods to which the export support regime does not apply, namely:

the export of specific types of goods outside the customs territory of Ukraine as supplies by commercial vehicles in accordance with Article 229 of the Customs Code of Ukraine;

the export of specific types of goods (commodity subcategories 1001 91 10 00, 1002 10 00 00, 1003 10 00 00, 1004 10 00 00, 1005 10 13 00, 1005 10 15 00, 1005 10 18 00, 1201 10 00 00, 1205 10 10 00, 1206 00 10 00 in accordance with the Ukrainian Classification of Goods for Foreign Economic Activity (UKT ZED)), carried out by VAT payers accompanied by a phytosanitary certificate issued in accordance with the provisions of paragraph ¹⁵ of Section IX of the Law of Ukraine ‘On Plant Quarantine’.

We would like to emphasise that tax invoices issued for transactions involving the export of certain types of goods, which are to be taken out of the customs territory of Ukraine under the export guarantee regime after 1 December 2024, cannot be registered in the Unified Register of Tax Invoices (hereinafter – the URT) until 1 December 2024 (prior to the introduction of the export guarantee regime).

We would also like to remind you that, in accordance with paragraph 3 of the Procedure for Maintaining the UTR, approved by Resolution of the Cabinet of Ministers of Ukraine No. 1246 of 29 December 2010, as amended (hereinafter – Procedure No. 1246), the operating day runs on working days from 08:00 to 20:00.

The registration of tax invoices and/or adjustment calculations reflecting the export of certain goods outside the customs territory of Ukraine (under the export guarantee regime) is carried out within three operating days from the date of their submission for registration in the Unified Register of Tax Invoices (paragraph 27 of Procedure No. 1246).

The State Tax Service’s clarifications regarding the specifics of carrying out operations involving the export of certain types of goods outside the customs territory of Ukraine under the export regime (under the export guarantee regime) are set out in the State Tax Service’s letters dated 02.07.2024 No. 19083/7/99-00-21-03-02-07 and dated 15 November 2024 No. 31717/7/99-00-21-03-02-07, which are available on the State Tax Service web portal via the following links: https://tax.gov.ua/zakonodavstvo/podatkove-zakonodavstvo/listi-dps/79021.html and https://tax.gov.ua/zakonodavstvo/podatkove-zakonodavstvo/listi-dps/79183.html respectively.

Questions and answers regarding the specifics of tax accounting for transactions involving the export of certain types of goods outside the customs territory of Ukraine under the export customs regime, in connection with the introduction of the export guarantee regime from 1 December 2024, can be found here.