Importing from Ukraine to the EU

Ukraine is an important trading partner for Slovak companies, and for many of them the Slovak–Ukrainian border is the gateway for goods entering the European Union. Although trade takes place under a free trade agreement, an import from Ukraine is still an import from a third country: it requires a customs declaration, proof of origin and, for some commodities, special controls. Below is a step-by-step overview of the process.

Legal framework for EU–Ukraine trade

Trade is governed by the Deep and Comprehensive Free Trade Area (DCFTA), which forms part of the EU–Ukraine Association Agreement. Customs duties have been eliminated for most industrial products, while tariff-rate quotas apply to sensitive agricultural products.

The temporary Autonomous Trade Measures (ATM), which liberalised almost all imports from Ukraine after 2022, expired on 5 June 2025. They were replaced by a revision of the DCFTA, which entered into force on 29 October 2025, adjusts quotas mainly for sensitive commodities (e.g. sugar, poultry, eggs, wheat, maize, honey) and contains a safeguard clause. Before importing agricultural commodities, always check the current status of the quotas.

Step 1: Classifying the goods and determining the duty rate

The starting point is the correct Combined Nomenclature (CN) code. It determines the duty rate, eligibility for preference, any quota, the VAT rate and non-tariff measures (licences, veterinary or phytosanitary requirements). You can check current rates and measures in the TARIC database.

Step 2: Proof of preferential origin

Zero or reduced duty applies only to goods with preferential origin from Ukraine. The rules of origin are based on the regional Pan-Euro-Mediterranean (PEM) Convention. Origin is proven mainly by:

a EUR.1 movement certificate, or
an origin declaration on the invoice (e.g. by an approved exporter, or for consignments up to a set value).

Without valid proof of origin, the standard third-country duty applies.

Step 3: EORI registration and representation

The importer needs an EORI number. A foreign company without an EORI number can use an indirect customs representative, who acts in its own name on behalf of the importer. Under direct representation, the representative acts in the name and on behalf of the importer (Article 18 UCC). Under indirect representation, the customs representative is jointly liable for the customs debt, which also affects the amount of the required guarantee.

Step 4: Entry summary declaration (ENS) in ICS2

Since 2025, the ICS2 Import Control System also covers road and rail transport. The carrier (or another responsible person) must lodge an entry summary declaration (ENS) with the required safety and security data before the goods arrive at the EU border.

Step 5: Transport and border crossing

The main road crossing for freight on the Slovak–Ukrainian border is Vyšné Nemecké – Uzhhorod; rail freight passes mainly through Čierna nad Tisou. At the border, goods are either cleared directly or continue under transit (NCTS, T1) to an inland customs office or a customs warehouse. Border waiting times vary considerably, so it pays to plan with a buffer.

Step 6: Choosing the customs procedure

Procedure 40 – free circulation: customs duty (if applicable) and import VAT are paid; the goods remain in Slovakia.
Procedure 42 – free circulation with VAT exemption: if the goods continue to a customer in another Member State (Czechia, Poland, Hungary…), no VAT is paid in Slovakia, subject to the conditions of § 48(3) of the Slovak VAT Act.
Customs warehousing: payment of duty and VAT is deferred until the goods are removed from the warehouse.

Step 7: Controls and non-tariff measures

Food, feed, plants and animal products are subject to veterinary or phytosanitary controls at designated border control posts. In recent years Slovakia has also applied national restrictions on imports of certain agricultural commodities from Ukraine. Their scope has changed over time, so always check the current situation before trading.

Step 8: VAT and accounting

A VAT payer generally deducts import VAT in its VAT return. Since 1 July 2025, importers established in Slovakia that hold an AEO authorisation apply self-assessment under § 84a of the Slovak VAT Act, so they do not pay VAT to the customs office at all.

Frequently asked questions

Is customs duty payable on imports from Ukraine?

For most industrial goods with proven Ukrainian origin, no. For certain agricultural products tariff-rate quotas apply, and duty is payable above them.

What proof of origin do I need?

Most commonly a EUR.1 movement certificate or an origin declaration on a commercial document under the PEM rules.

Can a Ukrainian company import goods into the EU itself?

Yes, with an EORI number and usually through a customs representative in the EU. When selling to customers in another EU Member State, procedure 42 with a tax representative is advantageous.

Do the goods have to be cleared directly at the border?

No. They can continue under NCTS transit to an inland customs office or a customs warehouse.

Importing from Ukraine? Entity & Company, s.r.o. handles the entire process – from tariff classification and proof of origin through transport to customs clearance under procedure 40, procedure 42 or customs warehousing. We communicate in Slovak, Ukrainian and English. See our customs services and freight transport, or contact us at info@entity-company.com and +421 55 381 6786.