We present a concise clarification of the current legislative framework governing the electronic excise stamp system (e-Excise), which has recently become the subject of numerous inquiries.
At present, both state authorities and certain taxpayers are actively preparing for the full-scale implementation of the electronic excise stamp system. Such activity reflects the state’s commitment to strengthening control over the circulation of excisable goods and combating illicit production. What does this mean for taxpayers, and what should be expected in the near future?
Pursuant to the Law of Ukraine “On Amendments to the Tax Code of Ukraine and Other Laws of Ukraine in Connection with the Introduction of Electronic Traceability of the Circulation of Alcoholic Beverages, Tobacco Products, and Liquids Used in Electronic Cigarettes” dated 29 June 2023, No. 3173-IX, beginning in 2026, control over the circulation of alcoholic beverages, tobacco products, and liquids for electronic cigarettes will be carried out through electronic excise stamps. The e-Excise system will provide for the generation of serial numbers, formation of unique identifiers, activation, deactivation and cancellation of electronic excise stamps, as well as the recording of product movement in the excise electronic document.
Under the same Law No. 3173-IX, an electronic excise stamp is defined as a dataset consisting of a unique identifier and other information within the Electronic System of Circulation of Alcoholic Beverages, Tobacco Products and Liquids Used in Electronic Cigarettes. This enables the identification of each unit of goods subject to marking at all stages of circulation.
Furthermore, according to the Law of Ukraine “On State Regulation of the Production and Circulation of Ethyl Alcohol, Distillates, Bioethanol, Alcoholic Beverages, Tobacco Products, Tobacco Raw Materials, Liquids Used in Electronic Cigarettes, and Fuel” dated 18 June 2024, No. 3817-IX, the electronic system of circulation of alcoholic beverages, tobacco products, and liquids used in electronic cigarettes is an information and communication system that ensures the creation of electronic excise stamps, processing and storage of data on goods subject to marking, as well as electronic interaction between state authorities, legal entities, and individuals (including individual entrepreneurs) to ensure electronic traceability of the circulation of such goods.
The full launch of the electronic excise stamp system is currently scheduled for 1 January 2026. A test mode for certain categories of excisable goods was introduced on 1 March 2025. During this test period, which lasts until 31 December 2025, products must still be marked with paper excise stamps in accordance with the applicable procedure. Additional graphic elements of the electronic stamps may be applied, provided that they do not obscure the QR code, barcode, or other requisites of the paper stamp.
In general, the introduction of the electronic excise stamp represents a significant step towards strengthening control over the excise goods market, reducing the shadow economy, and increasing budget revenues. The benefits and positive effects of implementing such a system include legalization of the market and reduction of illegal products, protection against counterfeit goods, automation of excise stamp reporting, reduction in the use of paper forms, and a level playing field for legitimate market participants. However, one of the main challenges is that the competent state authorities have not adopted all the necessary by-laws in time to ensure effective testing and subsequent full implementation of the system.
It should also be noted that producers and importers of alcoholic beverages, tobacco products, and liquids for electronic cigarettes will be required to implement substantial operational changes and invest in new marking and accounting systems. At present, not all market participants are adequately prepared for these requirements.
Author: Dmytro Dovzhyk, Attorney at Law and Partner at ArtesLex
16 July 2025
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