The Cabinet of Ministers of Ukraine has excluded the Ukrainian Classification of Goods for Foreign Economic Activity (UCGFEA / UKTZED) code under which energy storage systems (ESS) are imported from the list of goods subject to import licensing due to the presence of controlled substances. The relevant amendments were approved by Government Resolution No. 102 dated January 29, 2026.
This decision is the result of systematic advocacy by the Ukrainian Business Association SUP (Union of Ukrainian Entrepreneurs) and its Analytical Center, which initiated a regulatory review following appeals from businesses in the renewable energy sector (@Sansei Energy).
What was the issue
By Resolution of the Cabinet of Ministers of Ukraine No. 1795 dated December 31, 2025, a list of goods and equipment that may contain controlled substances (ozone-depleting substances and fluorinated greenhouse gases) subject to export and import licensing for 2026 was approved.
This list included UKTZED code 8507 60 00 00, under which energy storage systems are imported. As ESS contain a controlled substance — the fluorinated greenhouse gas R134a — businesses were required to obtain an import license for each shipment.
At the same time, this gas:
is used exclusively as a refrigerant in a hermetically sealed thermal management and cooling system;
is not intended for extraction, refilling, or separate circulation;
does not pose additional environmental risks during ESS operation.
Impact on business
The requirement to obtain a license for every shipment:
significantly delayed import timelines;
created additional administrative burdens for businesses;
complicated the implementation of projects during a critical period for Ukraine’s energy system.
SUP’s approach
SUP’s Analytical Center prepared substantiated analytical materials and formally addressed the Ministry of Economy, Environment and Agriculture, proposing to remove the regulatory barrier.
In its arguments, SUP emphasized that:
the state simultaneously stimulates imports of energy equipment (including VAT exemptions extended until 2029) while creating regulatory obstacles;
licensing in this case blocks the rapid deployment of solutions critical to the stability of the energy system;
the implementation of energy storage systems can reduce the load on the national power grid and strengthen the economy’s resilience.
Outcome
The Government supported the business arguments and excluded the item
“Lithium-ion electric batteries, including separators, UKTZED code 8507 60 00 00”
from Annex 3 to Resolution No. 1795.
This decision results in:
the cancellation of import licensing for energy storage systems;
significant simplification of customs procedures;
faster implementation of energy projects;
reduced regulatory pressure on businesses without compromising environmental protection.
Broader significance
This case demonstrates how structured dialogue between business and government, supported by data and analysis, enables the swift removal of regulatory barriers.
SUP’s Analytical Center will continue to focus on root causes rather than symptoms, shaping solutions that work simultaneously for business, the state, and the economy.