Joint statement by the business community on the situation regarding the introduction of electronic traceability of excise goods

19/ 06/ 2025

The American Chamber of Commerce in Ukraine, the European Business Association, the Ukrtyutyun Association, the Ukrspirt Association, the Ukrainian Food Retail Alliance, the Union of Ukrainian Entrepreneurs, and the National Retail Association draw attention to the critical situation surrounding the implementation of the Electronic System for the circulation of alcoholic beverages, tobacco products, and e-cigarette liquids, as stipulated by Law of Ukraine No. 3173-IX. The business community supports the introduction of the electronic excise stamp as an important step towards the digitalisation of excise goods control and tackling the shadow market. At the same time, it emphasises that without comprehensive testing, and verification of the reliability and stability of all components of the Electronic System, its uninterrupted functioning cannot be guaranteed — and thus, neither can the achievement of its core objective: strengthening control to ensure full tax collection on excise goods and counteracting their illegal production and circulation. According to the current legislation, the Government was required to adopt the necessary secondary legislation by 27 January 2024 and to ensure testing of the Electronic System starting from 1 March 2025. However, these regulatory acts have not yet been adopted, and the roadmap of the Ministry of Digital Transformation of Ukraine foresees system readiness for productive operation only by the end of 2025 — without the availability of offline mode software solutions. This contradicts the requirements of Law No. 3173-IX, undermines timely business preparedness, and creates technical risks and operational uncertainty. Should the Electronic System be launched from 1 January 2026 without thorough testing of all components and stable access to its full functionality, there is a serious risk of disruptions in the supply of legal goods, a surge in the shadow market, and significant losses to the state budget — outcomes that are unacceptable in a time of martial law. In light of this, the aforementioned business associations call on the relevant state authorities to urgently provide the business community with clear information regarding: the date of adoption of the mandatory secondary legislation; the date of readiness of the Electronic System for full-scale operation, including offline-capable software solutions. Furthermore, business urges the Government to ensure the opportunity for proper testing and implementation of the full Electronic System over a period no shorter than currently envisaged in Law No. 3173-IX, by introducing the necessary amendments to legislation on the electronic traceability of excise goods. Only such an approach will allow the Electronic System to fulfil its intended purpose, give businesses sufficient time for technical adaptation, avoid disruptions, safeguard stable budget revenues, and prevent the growth of the shadow market. The business community reaffirms its willingness to engage in constructive dialogue with government authorities and Members of Parliament on the urgent need to finalise the development of the Electronic System, adopt all necessary secondary legislation, and work on appropriate legislative amendments.

The business community supports the introduction of the electronic excise stamp as an important step towards the digitalisation of excise goods control and tackling the shadow market. At the same time, it emphasises that without comprehensive testing, and verification of the reliability and stability of all components of the Electronic System, its uninterrupted functioning cannot be guaranteed — and thus, neither can the achievement of its core objective: strengthening control to ensure full tax collection on excise goods and counteracting their illegal production and circulation.

According to the current legislation, the Government was required to adopt the necessary secondary legislation by 27 January 2024 and to ensure testing of the Electronic System starting from 1 March 2025. However, these regulatory acts have not yet been adopted, and the roadmap of the Ministry of Digital Transformation of Ukraine foresees system readiness for productive operation only by the end of 2025 — without the availability of offline mode software solutions. This contradicts the requirements of Law No. 3173-IX, undermines timely business preparedness, and creates technical risks and operational uncertainty.

Should the Electronic System be launched from 1 January 2026 without thorough testing of all components and stable access to its full functionality, there is a serious risk of disruptions in the supply of legal goods, a surge in the shadow market, and significant losses to the state budget — outcomes that are unacceptable in a time of martial law.

In light of this, the aforementioned business associations call on the relevant state authorities to urgently provide the business community with clear information regarding:

the date of adoption of the mandatory secondary legislation;
the date of readiness of the Electronic System for full-scale operation, including offline-capable software solutions.

Furthermore, business urges the Government to ensure the opportunity for proper testing and implementation of the full Electronic System over a period no shorter than currently envisaged in Law No. 3173-IX, by introducing the necessary amendments to legislation on the electronic traceability of excise goods.

Only such an approach will allow the Electronic System to fulfil its intended purpose, give businesses sufficient time for technical adaptation, avoid disruptions, safeguard stable budget revenues, and prevent the growth of the shadow market.

The business community reaffirms its willingness to engage in constructive dialogue with government authorities and Members of Parliament on the urgent need to finalise the development of the Electronic System, adopt all necessary secondary legislation, and work on appropriate legislative amendments.