Registry of Controlled Substance Operators: Why Import Licensing Is Impossible Without It

Businesses planning to import controlled substances or goods containing them often focus solely on obtaining a license from the Ministry of Economy. However, in practice, there is another mandatory step without which it is impossible to obtain an import license for controlled substances, including ozone-depleting substances and fluorinated greenhouse gases: registration in the Unified State Register of Operators of Controlled Substances.

This is precisely the stage where businesses often face refusals, requests to revise their documents, and supply delays. That is why it is important to understand why this register is required, who maintains it, and how to properly complete the registration process.

What Is the Register of Operators of Controlled Substances?

The Unified State Register of Operators of Controlled Substances is a government information database containing information about business entities that carry out operations involving controlled substances and products containing them. Being listed in the register confirms that a business has been officially identified by the state as an operator in the relevant field and can subsequently undergo procedures related to the licensing of imports or exports.

To be included in the register, an applicant must submit a set of documents, including:

• an application in the prescribed form (a sample of the completed application is available here);
• information required for inclusion in the Unified State Register of Operators of Controlled Substances;
• a cover letter.

The information includes details such as the planned types of operations involving controlled substances, the planned types of operations involving products and equipment containing controlled substances, whether the company employs individuals who hold a qualification document authorizing them to work with such substances and/or products, and other relevant information.

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Which Authority Maintains the Register and How Does It Interact With the Ministry of Economy?

The formation and maintenance of the Register of Operators of Controlled Substances falls within the competence of the authorized state authority responsible for protecting the ozone layer and regulating fluorinated greenhouse gases, namely the Ministry of Economy, Environment and Agriculture of Ukraine. Until 2025, these functions were handled by two separate ministries, the Ministry of Economy and the Ministry of Environmental Protection and Natural Resources. The two ministries were subsequently merged.

Once a business entity has been included in the register, the relevant information is used when reviewing documents related to the licensing of foreign economic operations.

This is why registration in the register and obtaining an import license are effectively interconnected stages of the same process. Any errors at the first stage may complicate or delay the process of obtaining the license at the second stage.

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Why You Need to Be Included in the Register Before Obtaining an Import License

Controlled substances and goods containing them are subject to special government regulation. To import them, a business entity must obtain the import license. At the same time, one of the key elements of the licensing procedure is confirmation that the applicant is included in the Unified State Register of Operators of Controlled Substances.

In practice, registration as an operator of controlled substances is a prerequisite for subsequently obtaining an import license. If a business is not included in the register, the licensing procedure cannot be successfully completed.

Therefore, it is advisable to start the process by applying for inclusion in the register and only then proceed with obtaining an import license for controlled substances.

What Happens if You Do Not Register as an Operator of Controlled Substances?

The most obvious consequence is the inability to obtain a license to import controlled substances or products containing them. However, the risks do not end there. Without the required license, a business may also face difficulties completing customs clearance of the goods on time, which can result in additional costs due to the goods being held at customs.

For companies working with refrigeration equipment, air conditioners, heat pumps, aerosol products, or other goods containing controlled substances, such delays can lead to significant financial losses.

What to Consider When Preparing Documents for the Register

Companies often try to go through this process step by step without conducting a preliminary audit. A common scenario is that a contract is signed with a foreign supplier, the goods are shipped to the border, and only then does the company start gathering the required documents. This is where the main obstacle often arises: the Ministry of Economy rejects the application.

It is worth noting that most problems are not caused by missing documents, but by simple errors in how they are prepared. Particular attention should be paid to the consistency of the information: the data provided in the application and other documents must match.

Any inaccuracy in the documents may result in the application being returned for revision. In practice, this can mean weeks of waiting. While the documents are being reviewed and resubmitted, the goods may remain in the customs control area. The resulting costs, including demurrage and terminal fees, can exceed the net profit from the shipment itself.

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What to Do If You Need to Complete the Process Quickly and Avoid Refusals

To avoid delays and downtime at customs, it is advisable to engage legal counsel specializing in foreign economic activity before signing contracts or shipping the goods.

Our lawyers assist with procedures related to the import and export of controlled substances and goods containing them. Within the required timeframes, we can:

• analyze your documents and determine whether a license is required in your particular case and whether any changes need to be made to the existing documents, such as the contract;
• prepare the documents required for inclusion in the Register of Operators of Controlled Substances;
• eliminate risks associated with improperly prepared documents;
• assist with communication with government authorities;
• prepare documents for obtaining an import or export license;
• provide comprehensive legal support throughout the process of obtaining an import or export license for goods containing ozone-depleting substances.

Our approach helps avoid refusals, shorten processing times, and ensure the continuity of international supplies.

Planning to import controlled substances or equipment containing them? Contact us. We will help you complete the registration process in the Unified State Register of Operators of Controlled Substances and obtain the required license.

Learn more about our foreign economic activity legal services here.