Ukraine's eExcise: What Businesses Need to Know and Prepare For

What actually changes

An excise stamp used to be a physical form: you bought it, received it, glued it on. Now the stamp is a record in the Electronic System for the Circulation of Alcoholic Beverages, Tobacco Products and Liquids Used in Electronic Cigarettes - known as eExcise.

The state generates a unique identifier, the economic operator applies it to the packaging as a DataMatrix code, then activates the stamp and pays excise tax. From that point the system tracks the goods: movement between facilities, transfer to another operator, and the final sale through a cash register.

Ukraine adopted the eExcise Law No. 3173-IX in June 2023, aligning with European directives against the illegal tobacco trade. A comparable system, Tobacco Track & Trace, has operated in the EU since 2019.

The practical consequence: stamp handling moves out of accounting and the warehouse floor into a web interface - and, for anyone working at volume, into their own software.

Key dates

Note the API date - it falls before the launch. If a contractor or ERP vendor has already built an integration for you, confirm it targets the current API version.

A transition period applies to penalties: for the first six months after launch, fines for violations may be limited to 10% of the standard amount, rising to 30% until 31 December 2026. This softens the landing, but it does not postpone the obligation to mark.

Who is affected

A participant in the system is called an economic operator (EO): a business that produces excisable goods within the customs territory of Ukraine, imports them, or trades them wholesale or at retail.

• Producers - apply the stamp during production

• Importers - ensure marking before import or under the customs warehouse regime

• Wholesalers and logistics warehouses - document movements with an Excise Electronic Document

• Retailers - redeem the stamp at the point of sale through a cash register

Eligible registrants include Ukrainian legal entities, sole proprietors, separate subdivisions of foreign legal entities, and persons authorised to keep records under a joint activity agreement. A valid licence for the relevant activity is mandatory. Registration is submitted online through the eExcise web interface and signed with a qualified electronic signature.

Generation of unique identifiers, activation, deactivation and redemption of electronic excise stamps are provided free of charge.

What the electronic excise stamp looks like

Marking requirements are set by the Marking Procedure approved by Resolution No. 890 of the Cabinet of Ministers of Ukraine dated 16 July 2025.

• DataMatrix ECC 200 code, symbols in accordance with DSTU ISO/IEC 16022

• Alongside it - the first twelve characters of the unique identifier, in human-readable form

• Minimum print quality - grade 2 under ISO/IEC 15415

• The application method must prevent replacement, reuse or alteration of the code, and must not obscure other mandatory information on the packaging

The print quality requirement deserves emphasis. Grade 2 is a legal norm, not a recommendation. A code printed below that standard renders the goods unmarked, with all the consequences that follow - even if it looks fine to the eye.

As for scanners, no list of approved models exists and none is planned: the regulator has confirmed that no requirements for specific scanners or software will be imposed, referring instead to GS1 standards. What matters is capability - the device must read DataMatrix ECC 200 in line with DSTU ISO/IEC 16022. In practice this rules out ordinary laser barcode scanners, which physically cannot see a two-dimensional code. Image-based scanners are required.

Group packaging and the UGI

When individual units are packed into cases and cases onto pallets, each level receives a Unique Group Identifier (UGI). The UGI records which stamps belong to which case, and which cases belong to which pallet, so that a whole pallet can move through the system as a single entity.

Two practical points. Nesting is limited in depth, and a code that already belongs to one group cannot simply be moved into another - it must first be detached. Repacking pallets is therefore a deliberate operation, not something done on the fly.

A special case: tobacco products

For cigarettes, cigars and heated tobacco under UKTZED codes 2402 20 90 10, 2402 20 90 20, 2402 10 00 90 and 2404 11 00 10, a separate rule applies: the graphic element is applied directly during production to the individual pack. Marking such products at a separate site after production is not permitted.

For all other goods - alcohol, e-liquids, other tobacco - the code may be applied to any surface of the individual package.

Where marking happens for imports

The Procedure allows exactly three lawful moments of application, all of them before release into free circulation:

1. During production within the customs territory of Ukraine

2. Before import into Ukraine - that is, abroad

3. Under the customs warehouse regime, prior to release into free circulation

Clearing customs first and marking later, before sale, is not a lawful option.

An important detail for importers and their foreign suppliers: the Procedure expressly permits transferring unique identifiers and graphic elements of stamps to other business entities for application. In other words, a foreign producer or a specialised site abroad may apply the marks on your behalf - a legitimate arrangement, not a grey area. Responsibility toward the state nevertheless remains with the importer, who orders the codes, pays the tax and activates the stamps.

For foreign suppliers this raises a practical question worth settling early: whether you are prepared to receive code files from your Ukrainian partner and apply DataMatrix codes on your line, or whether marking will be handled at a third-party site or a customs warehouse in Ukraine.

What to prepare

• Registration as an economic operator and appointment of authorised representatives with defined rights

• Qualified electronic signature - every document in the system is signed by an authorised representative

• Valid licences for your activities - the system verifies them automatically

• Equipment - a printer capable of consistently achieving grade 2, and image-based 2D scanners

• Warehouse processes - scanning, forming group packages, handling exceptions

Web interface, offline application, or your own software

There are three ways to work with eExcise.

The web interface covers the full cycle: ordering codes, paying tax, activating stamps, forming UGIs, issuing Excise Electronic Documents, and generating extracts and analytical reports. For companies with modest volumes this is entirely sufficient - these amount to dozens of operations per month, not thousands.

An offline application is also provided for economic operators. It supports work without connectivity for up to 72 hours and covers viewing stamps, forming and entering UGIs, issuing Excise Electronic Documents and reviewing stock reports. For warehouses with unreliable connectivity this is worth evaluating before commissioning anything custom.

Your own software becomes necessary in two situations. First, when codes must be sent to an industrial printer: the web interface exports page by page in PDF, which no production printer can consume - a programmatic export is required. Second, when the volume of scanning at packing demands a dedicated workstation.

Integration with an accounting system such as BAS or 1C is a separate question. It is needed not for legal compliance but to avoid entering the same documents twice.

Common pitfalls

A few things that are not spelled out in the manuals but will halt work on day one.

• Tax debt blocks code issuance. The system checks for outstanding debt when identifiers are generated. If debt exists, the order will not go through

• Permissions by UKTZED code. Operations require registered permissions for the specific commodity codes in your product range

• The tax payment window is 15 days. After that the amount becomes tax debt - and debt, as noted above, blocks new orders

• Pallets cannot be repacked on the fly. A code already included in a group package must first be detached

• Laser scanners do not read DataMatrix. Check your equipment in advance, not during the pilot

Where to start

1. Verify registration as an economic operator, licence validity and availability of qualified electronic signatures

2. Check the two blockers - tax debt and UKTZED permissions for your product range

3. Decide where marking will physically take place, and allow time for contracting, equipment supply and print setup

4. Use the testing environment from 1 August 2026 to rehearse the full chain before it becomes mandatory

5. Run the full chain on one small batch: order codes, print, apply, form group packages, import, activate

6. Train staff on that same pilot - on a live process, not from a manual

7. Scale up, and only then consider accounting system integration

The key planning point: the decision on where marking takes place sits on the critical path. Everything after it - contracts, equipment delivery, print setup and quality validation - is measured in weeks, not days.

Need help

IT-Master supports marking implementation projects: requirements analysis for a specific product range, equipment selection, development of code export modules and aggregation workstations, and integration with accounting systems. If you are still at the stage of sizing the work, start with a readiness audit - it takes a few days and reveals the real scope.

Prepared as of July 2026 on the basis of official eExcise project materials. Regulations and system functionality continue to evolve - verify current requirements against official project resources.