Draft Law No. 15316: amendments to the Customs Code regarding operations with excisable goods at customs warehouses and liability for customs payments

On 12 June 2026, Draft Law No. 15316 was published on the website of the Verkhovna Rada of Ukraine. The Draft Law proposes amendments to the Customs Code of Ukraine aimed at regulating certain customs procedures.

Key provisions of Draft Law No. 15316: 

• permits new operations with excisable goods (alcohol, tobacco, e-cigarette liquids) placed under the customs warehouse regime — in particular, labelling and packaging — without authorisation from the customs authority (notably for enterprises authorised to apply the "release at the place of location" simplification);

• revises the scope of persons jointly and severally liable for the payment of customs duties; 

• provides that the exceeding of transit time limits during the period of martial law shall not be taken into account when assessing the enterprise's compliance with the criteria required for authorisations.

The proposed amendments represent a targeted refinement of existing rules, aimed at eliminating practical ambiguities and adapting the regulatory framework to the actual needs of businesses and customs authorities. 

I. New opportunities for operations with excisable goods

Significant changes concern usual forms of handling of goods placed under the customs warehouse regime, including excisable goods, namely: 

• packaging, unpackaging, and repackaging (without changing the UCGFEA code);

• labelling, including the affixing of excise stamps; 

• application of unique group identifiers and their updating upon regrouping of goods.

Such operations may be carried out without authorisation from the customs authority at premises of enterprises authorised to apply the "release at the place of location" simplification. Other usual forms of handling of goods at such premises may be performed only with authorisation from the customs authority, which is required to issue a decision (or a reasoned refusal) within 3 working days from the date of submission of the application. 

The expansion of permissible operations with excisable goods is a positive signal for importers and distributors, as it allows for more flexible organisation of logistics and goods turnover without unnecessary administrative burden.

II. Reallocation of liability for customs payments 

The Draft Law revises the approach to identifying persons jointly and severally liable for the payment of customs duties. In particular:

• the liability of an enterprise that uses a comprehensive guarantee or an exemption therefrom is abolished; 

• instead, the liability of infrastructure operators is expanded (holders of customs warehouses, temporary storage warehouses, the head of the recipient organisation of humanitarian aid, and holders of enterprise premises specified in the authorisation to apply a simplification) in cases of loss or unlawful release of goods.

Liability is thus more clearly tied to the entities that actually control the goods. Businesses that act as holders of customs warehouses or temporary storage warehouses are advised to review their internal procedures for goods control in order to minimise risks. 

III. Mitigation of the consequences of breaching transit time limits during martial law

It is envisaged that exceeding the transit transportation time limits during the period of martial law (regardless of the number of instances) shall not be taken into account when assessing the enterprise's compliance with the criterion set out in paragraph 1 of part 3 of Article 12 of the Customs Code (in particular, for obtaining AEO status and authorisations to apply simplifications). 

This will help businesses avoid negative consequences caused by delays resulting from objective logistical constraints.

Overall, if adopted, the Draft Law will streamline customs procedures for businesses, provide greater flexibility in handling goods, and more clearly define the liability of the parties involved. This should enhance the predictability and stability of conducting foreign economic activity. 

How PwC can support your business

1. Customs Audit: from risk identification to optimisation of foreign economic operations
   A comprehensive review of foreign trade activities aimed at minimising customs risks, optimising costs, and enhancing process efficiency. We help assess the accuracy of tariff classification, customs valuation, application of preferences, and documentary formalities, as well as implement practical solutions to strengthen compliance and accelerate customs procedures.

2. Representation in customs disputes: from pre-trial settlement to judicial defence
   We support companies in their interactions with customs authorities — from analysing disputes and challenging decisions on classification and customs valuation to representation in court. We help mitigate risks, protect business interests, and ensure effective resolution of customs matters at every stage.

3. Authorised Economic Operator: from readiness assessment to obtaining authorisation
   We support companies through all stages of obtaining AEO status: from compliance assessment and development of internal procedures to liaising with customs authorities during inspections. We help structure the process, mitigate risks, and successfully secure the status together with the simplifications it provides.

4. Customs legislation: from advisory services to comprehensive support of foreign economic activity
   We provide practical support on customs regulation matters — from advice on classification, customs valuation, preferences, and procedures to the review of transactions, documents, and interactions with customs authorities. We help ensure compliance with the law, mitigate risks, and improve the efficiency of foreign economic activity.

5. Comprehensive optimisation of logistics and supply chains: from analysis to implementation of solutions
   We help optimise import and export operations as well as logistics processes — from the analysis of customs regimes and business processes to the structuring of foreign economic activity, tax planning, and the implementation of practical solutions. We contribute to cost reduction, efficiency gains, and ensuring compliance with regulatory requirements in Ukraine and the EU.