Import of chemistry to Ukraine: how to import goods into Ukraine if there are questions about its chemical composition?

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The phrase “import of chemicals” sounds very serious, and in practice entrepreneurs are apprehensive about the complexity of such imports. On the other hand, not all entrepreneurs understand that by purchasing a batch of goods they will be dealing with imported chemicals.

After all, chemicals are all the familiar household items, such as shampoo and soap, and chemistry is also needed to make simple things such as clothes, shoes, and food.

If the goods you are planning to import have a complex chemical composition, you should first check the composition and make sure that you comply with all the rules of import. In Ukraine there is a large number of chemical substances and compounds, which require a special registration regime for import. It is important to understand when it is necessary and when there will be no questions about your goods.

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What affects the success of importing household or other chemicals?

The first and most important thing, which will affect the problem-free clearance of goods, is its correct classification with respect to the UCGFEA (Ukrainian Classifier of Goods for Foreign Economic Activity).

The UCGFEA is synchronized with the Harmonized Commodity Description and Coding System. What does this mean?

That the coding of goods in all countries that have adopted this system coincides at the level of the first 6 characters. In theory, this means that Ukrainians must clear the goods under the code under which it was declared by the exporter. But in practice, this position will help Ukrainian businessmen more in court, and when clearing the goods, they should really understand what they are and clear them under the correct code.

In addition, you should not have high hopes for the correctness of the exporter’s declaration of goods, since its task is to sell the goods, and the customs clearance is the task of the client. For example, an exporter may declare all textile-auxiliary substances under code 3809 (textile-auxiliary substances) without distinguishing silicones, adhesives, paints, which is critical for customs clearance.

When determining the code of goods in Ukraine, one should use the rules of interpretation, adopted specifically for the coding of goods. However, to understand them is not easy enough, because they also have many exceptions, in particular such as adhesives always go to the adhesives, silicones in silicones, regardless of their destination.

In order to determine the correct commodity code, you need to clearly understand the function of the product and its chemical composition, because when you have correctly identified the chemical code, you need to understand the legal requirements established for each product code.

These requirements may include:

Our specialists consider each case separately and make recommendations as to what permits and additional measures are necessary or not necessary. The main goal is not to take unnecessary actions that only increase the cost of importing goods, but to ensure their free importation.

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What should you pay attention to when importing chemicals into Ukraine?

There are certain exceptions and general rules that apply specifically in practice when importing chemicals. For example, the validity of the document on obtaining an Import License is required only if the goods are in aerosol packaging or contain ozone-depleting substances.

In this case, it is necessary to have a document on the chemical composition of the goods and to analyze the list of controlled substances approved by the government. You shall determine whether the imported goods have these substances. If there are none, then the goods do not need a license, despite the fact that the commodity code requires a license.

A common example is shampoo, a common shampoo that everyone uses every day. According to the commodity code, the shampoo requires an Import License for ozone-depleting substances, but there is very little chance that the shampoo actually contains substances that would deplete the ozone layer, so in practice you can import the shampoo without such a license.

Another example is equipment containing controlled substances, such as refrigerators containing refrigerant freeze (R134a). Such products already need an ozone-depleting substances import license because R134a is a controlled substance. However, in the case of refrigerators coming without frizzes, no license is required.

We offer a comprehensive approach that will help minimize all risks during customs clearance:

  • Determination of the commodity code depending on its chemical composition and purpose;
  • Determination of the need for additional permits and their subsequent receipt;
  • Execution of documents for import of chemical goods into Ukraine;
  • Assistance with customs clearance of goods in Ukraine, etc.

If necessary, we will help you organize the whole process of importing goods to Ukraine, from the organization of transportation, obtaining all necessary documents to the organization of customs clearance of the goods.

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Publication date: 10/05/2022

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