EBA proposals on business deregulation
The European Business Association has always advocated the need to deregulate business.
Over the past 55 days, the EBA has provided a number of point proposals to government agencies. They are designed to solve the most pressing problems and sustain business activities in wartime.
Moreover, the EBA fully supported the recent initiative of the Ministry of Economy to collect the proposals on deregulation from businesses and to create the most favorable conditions for doing business. After all, now is the time to stop bureaucratic procedures and build an efficient and fast system. In fact, the EBA has already shared these proposals with the Ministry of Economy.
Conventionally, business proposals can be divided into two categories – those that the EBA proposes to introduce temporarily during martial law and those that we propose to implement in national legislation on a permanent basis.
Temporary proposals include:
- Abolishing the list of critical imports (CMU Resolution “On the List of Critical Imports” №153) and allowing those companies that can conduct foreign trade operations to operate despite the martial law.
- Restoring VAT refunds to exporters.
- Liberalizing the labor taxes: to extend the effect of SSC benefits for mobilized workers to legal entities (as currently, only private individuals enjoy them) and to grant the right to use such benefits at the discretion of companies. Also, it is necessary to compensate the salaries of mobilized workers from the State Budge as companies continue to pay their employees who now serve in military service.
- Allowing the import of non-food products to Ukraine that do not comply with the requirements for product labeling in the Ukrainian language. As a result of hostilities, the usual supply chains were significantly damaged, which, in turn, makes it impossible to import goods from those plants and enterprises that produced goods for the Ukrainian market.
- Allowing the import of electrical and electronic equipment and radio equipment to Ukraine based on European declarations of conformity and CE marking. Currently, the import of a number of critical goods is complicated by the inability to prepare a Ukrainian declaration of conformity. Abolishing the requirement to accompany each unit of radio equipment with a declaration of conformity.
- Restoring the return of financial guarantees from the single treasury account of the State Customs Service.
- Abolishing veterinary laboratory control subject to the presence of an international veterinary certificate from the manufacturer.
- Extending for 1 year the current exemption from customs inspection of goods directly at checkpoints.
- Simplifying the requirements for filling out customs declarations. At the same time, setting reasonable deadlines for the submission of such documents after martial law.
- Postponing the date of entry into force of the Technical Regulation (TR) to cosmetic products. The systems of state control for the implementation of the TR do not work at the moment, and this direction is not a priority during martial law.
- Changing the procedure of environmental impact assessment (EIA): to introduce the electronic document management, to simplify the requirements for the preparation of the EIA reports, to reduce the time of the EIA procedure, to enable the prompt amendment to the EIA report, to extend the terms of EIA conclusions, to terminate post-project monitoring, as well as to resolve the issue with EIA for relocated companies.
- Settling the issue of exemption from certain taxes and approving the list of territories where hostilities are taking place/took place, etc. – because currently there is no such official list, and, accordingly, there are no benefits).
- Suspending the deadlines for the elimination of violations as required by the bodies of state supervision/control (the implementation of which was due to the period of martial law).
Proposals for the permanent implementation
- Abolishing the conclusions of the state sanitary-epidemiological examination for the goods covered by the technical regulations adopted in Ukraine. After all, the EU does not have such conclusions, and the quality and safety of products are determined by regulations and standards that have analogs in Ukraine.
- Allowing the use of English in user interfaces (eg, appliances, cars). After all, the translation of such interfaces is technically impossible in some cases or economically unjustified for a small batch of goods.
- Allowing manual use in electronic form. In today’s digital world, this is much more convenient, as it would not only allow more efficient use of resources but would also be more convenient for most consumers.
- Abolishing state regulation of prices (Resolution “On measures to stabilize prices for goods of significant social importance, anti-epidemic goods” №341).
- Finally, regulating e-commerce so that dishonest entrepreneurs do not have the possibility to sell goods/services online with impunity.
- Allowing the obtainment of permits for certain categories of construction not only in the State Environmental Inspectorate of Ukraine but also in the CNAP (centers for providing administrative services) and territorial inspections of DIAM (the State Inspectorate for Architecture and Urban Planning of Ukraine). Eliminating certain bureaucratic steps in issuing the certificate of commission.
- Revoking the paper license for wholesale/retail trade in alcoholic beverages, abolishing the obligation to keep records of excise tax stamps by type, canceling the special form of consignment note for alcoholic beverages, reviewing the approach to excise tax in advance, issuing excise stamps within 1 month from the date of the request and simplifying the procedure for registration of storage places for alcoholic beverages, etc.
The full list of EBA proposals can be found HERE.
We very much hope that the business proposals will be supported. It is not an easy time for anyone but business is ready to continue and revive economic activity!