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Business proposes to abolish the list of critical imports

24/ 03/ 2022
  Since the outbreak of the war, businesses have continuously provided all kinds of support to Ukraine, so it does not run short of essential products and goods. Companies continue to conduct business activities and support the state by paying taxes, providing humanitarian aid, etc. At the same time, the EBA community sees that the regulatory environment under martial law in Ukraine significantly limits the possibilities to sustain business activities. Unfortunately, many supply chains are now broken and it is very difficult, and sometimes impossible to continue business without importing products, ingredients, services, etc. Moreover, the effective currency regulation restricts settlements in foreign currency for business needs. The European Business Association is grateful to the Government and the Ministry of Economy of Ukraine for their readiness to consider promptly the proposals of the business community that resulted in a range of amendments to Government Decree №153 on the list of critical imports. However, the EBA is convinced that the best solution now is to abolish the Critical Import List and remove restrictions on foreign currency settlements so that companies, that still have the opportunity to conduct foreign economic transactions, could continue to work. By this, Ukrainian companies will be able to obtain the necessary raw materials and the cessation of production can be avoided. Moreover, the government strongly emphasizes the importance of business resumption/continuation. And if the List of Critical Imports cannot be abolished in the near future, it is extremely important to urgently remove the restrictions in Regulation №153 on the grounds for importing goods only in accordance with their description and allowing the import of goods and making foreign currency payments based on product/product group code or product description. Thus, some companies have already faced the situation that despite the UKTZED code of their product being included in the list of critical imports, banks do not allow payments for such goods in foreign currency (because the description of UKTZED code in Regulation №153 does not fully correspond to the product description).

Since the outbreak of the war, businesses have continuously provided all kinds of support to Ukraine, so it does not run short of essential products and goods. Companies continue to conduct business activities and support the state by paying taxes, providing humanitarian aid, etc.

At the same time, the EBA community sees that the regulatory environment under martial law in Ukraine significantly limits the possibilities to sustain business activities. Unfortunately, many supply chains are now broken and it is very difficult, and sometimes impossible to continue business without importing products, ingredients, services, etc. Moreover, the effective currency regulation restricts settlements in foreign currency for business needs.

The European Business Association is grateful to the Government and the Ministry of Economy of Ukraine for their readiness to consider promptly the proposals of the business community that resulted in a range of amendments to Government Decree №153 on the list of critical imports.

However, the EBA is convinced that the best solution now is to abolish the Critical Import List and remove restrictions on foreign currency settlements so that companies, that still have the opportunity to conduct foreign economic transactions, could continue to work. By this, Ukrainian companies will be able to obtain the necessary raw materials and the cessation of production can be avoided. Moreover, the government strongly emphasizes the importance of business resumption/continuation.

And if the List of Critical Imports cannot be abolished in the near future, it is extremely important to urgently remove the restrictions in Regulation №153 on the grounds for importing goods only in accordance with their description and allowing the import of goods and making foreign currency payments based on product/product group code or product description. Thus, some companies have already faced the situation that despite the UKTZED code of their product being included in the list of critical imports, banks do not allow payments for such goods in foreign currency (because the description of UKTZED code in Regulation №153 does not fully correspond to the product description).

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