EBA calls for amendments to the CMR form for the movement of alcoholic beverages

04/ 11/ 2026

The European Business Association has approached the Ministry for Communities and Territories Development of Ukraine, requesting amendments to the updated consignment note (CMR) form for the movement of alcoholic beverages, approved by Order No. 1024. Having reviewed the CMR form, EBA member companies identified a technical inaccuracy that could complicate the proper documentation of business transactions, particularly during the import and subsequent movement of alcoholic beverages. The discrepancy may create ambiguity in the preparation of CMRs, internal controls, accounting and confirmation of product receipt. This issue is particularly relevant for importers of alcoholic beverages, who use CMRs as one of the documents accompanying product movements and confirming the relevant receipt transactions. The incorrect designation of the consignees responsible representative creates additional operational and administrative challenges for companies. In this regard, the Association proposes a corresponding editorial amendment to the CMR form, replacing the wording ‘Handed over (consignees responsible representative)’ with ‘Received (consignees responsible representative)’. The business community also points out that the same inaccuracy appears in the updated consignment note form for the movement of ethyl alcohol and should also be corrected. Furthermore, the Association emphasises the need to provide an adequate transition period of at least six months for the implementation of the amended document form. International companies, in particular, use comprehensive ERP systems, accounting platforms and electronic document management systems, in which primary and accompanying document templates are integrated with other business processes. Accordingly, implementing the amendments requires time for technical adjustments, testing and coordination with the contractors involved. The Association supports the continued updating of transport documentation and the digitalisation of business processes. However, such changes should take the practical needs of businesses into account.

Having reviewed the CMR form, EBA member companies identified a technical inaccuracy that could complicate the proper documentation of business transactions, particularly during the import and subsequent movement of alcoholic beverages. The discrepancy may create ambiguity in the preparation of CMRs, internal controls, accounting and confirmation of product receipt.

This issue is particularly relevant for importers of alcoholic beverages, who use CMRs as one of the documents accompanying product movements and confirming the relevant receipt transactions. The incorrect designation of the consignee’s responsible representative creates additional operational and administrative challenges for companies.

In this regard, the Association proposes a corresponding editorial amendment to the CMR form, replacing the wording ‘Handed over (consignee’s responsible representative)’ with ‘Received (consignee’s responsible representative)’. The business community also points out that the same inaccuracy appears in the updated consignment note form for the movement of ethyl alcohol and should also be corrected.

Furthermore, the Association emphasises the need to provide an adequate transition period of at least six months for the implementation of the amended document form. International companies, in particular, use comprehensive ERP systems, accounting platforms and electronic document management systems, in which primary and accompanying document templates are integrated with other business processes. Accordingly, implementing the amendments requires time for technical adjustments, testing and coordination with the contractors involved.

The Association supports the continued updating of transport documentation and the digitalisation of business processes. However, such changes should take the practical needs of businesses into account.