Consumer Electronics, Regulatory Affairs
The obtainment of licenses for import/export of goods containing fluorinated greenhouse gases is significantly complicated as along with the application it is necessary to submit a foreign economic agreement and all bills (invoices) on which trade and economic activities were carried out under such an agreement. Therefore, the business emphasizes the need for simplification of the procedure. This was discussed on April 7 during a meeting of EBA member companies with representatives of authorities, in particular, the Ministry of Economy and the Ministry of Environment.
International companies established in Ukraine usually cooperate with their parent companies based on long-term contracts, which, in turn, forces business representatives to either re-sign foreign economic contracts or add copies of all invoices used over the years under the terms of such an agreement to the license application. This may end up generating thousands, and sometimes tens of thousands of pages. At the same time, according to the EBA member companies, businesses do not submit foreign economic agreements and/or invoices to the relevant state authorities when obtaining similar licenses in the EU member states.
For example, a company, that has been operating in Ukraine since 2003 and sells the equipment that falls under the category of goods containing fluorinated greenhouse gases, must provide all relevant invoices for 17 years when applying for a license.
Among other problematic issues, business representatives pointed out the inability to apply for licenses in electronic form through the Unified State Portal of Administrative Services because the e-application is not correct and for these reasons companies are denied applications.
Representatives of the Mineconomy promised to study the arguments presented by the business community and to explore the possibility of simplifying the procedure for obtaining a license, in particular, by eliminating the requirement to add a foreign economic agreement and all invoices to the license application.
Representatives of the Ministry of Environmental Protection invited participants to join the Google group to discuss issues and plans of the Ministry in the regulation of economic activities with ozone-depleting substances and fluorinated greenhouse gases.
The European Business Association is grateful for the openness to dialogue and constructive discussion. We hope that the voice of business will be heard and the procedure for obtaining a license to import goods that contain fluorinated greenhouse gases will be simplified so that companies can obtain licenses more quickly and not incur significant economic losses due to the suspension of export-import operations.
The need to obtain licenses for these goods is provided by Government Decree 1329 on the list of goods whose exports and imports are subject to licensing for 2021 and the requirements of Law 376-IX on the regulation of economic activities with ozone-depleting substances and fluorinated greenhouse gases.
The need to obtain licenses for these goods is provided by Government Resolution №1329 on the list of goods the exports and imports of which are subject to licensing for 2021 and the requirements of Law 376-IX on the regulation of economic activities with ozone-depleting substances and fluorinated greenhouse gases.