The sixth wave of annual survey of Ukrainian exporters and importers Theme 2. TRADE FACILITATION IN UKRAINE: customs procedures, appeals and digital products. Summary of key results.

1. The sixth wave of annual survey of
Ukrainian exporters and importers
Theme 2. TRADE FACILITATION IN UKRAINE:
customs procedures, appeals and digital products
Summary of key results
The study was conducted by the Institute for Economic Research and Policy Consulting as a part of
the project “Support for the Public Initiative “For Fair and Transparent Customs” with financial
support from the European Union, the International Renaissance Foundation, and Atlas Network

2. 2
Contents
THE MAIN RESULTS....................................................................................................................... 3
1. Structure of the surveyed enterprises..................................................................................... 5
2. Problems related to certain procedures.................................................................................. 5
2.1. "Advance customs clearance" procedure ........................................................................6
2.2. "Making decisions on product classification" procedure................................................... 7
2.3. "Making decisions on the customs value of goods" procedure..........................................8
2.4. "Material and commodity sampling" procedure............................................................... 9
2.5. "Obtainingcertificatesof originforgoodsatthe customs"/ "Providingcertificatesof origin
for goods during customs clearance" procedure....................................................................... 10
2.6. "Customs inspection of goods" procedure..................................................................... 11
2.7. "Post-customs audit" procedure................................................................................... 12
3. Cargo delays during customs control.................................................................................... 13
4. Should businesses agree with unreasonable customs demands to avoid downtime of goods? . 15
5. Appeals against the actions of customs authorities................................................................ 17
6. Single Window.................................................................................................................... 21
7. New computerized transit system(NCTS) ............................................................................. 23
8. AEO status.......................................................................................................................... 26
9. Digital products................................................................................................................... 29
Survey methodology................................................................................................................... 31
Distribution of respondents by region.......................................................................................... 32
Distribution of respondents by customs....................................................................................... 33
Customs postswhere businesses carry out registration ................................................................ 34

3. 3
THE MAIN RESULTS
Enterprises rarely report difficulties regarding going through customs clearance procedures.
Exporterspointto the complexityandlongdurationofprocedureswiththe requirementstoprovide
many documents. Importers see difficultiesin specific procedures (making decisions on customs
value and classification of goods). Delays of cargo at the border are still an urgent problem for
businesses, queues at the border being the main reason for this. The use of administrative appeal
as a tool for protectingone'srights was not common on the part of businesses.Businessestendto
adapt to the existing business climate in the field of foreign economic activity, even if it is not
perfect. 56.5% of respondents supported the idea that in order to avoid downtime of goods, it is
more expedient to agree with excessive (in their opinion) requirements of the customs than to
legally challenge the application of these requirements to a particular enterprise. Business
awareness about the new procedures (the NCTS and AEO status) and the new digital customs
products (“personal cabinet”, BI) is low. To improve the situation, it is recommended to apply
measuresto raise awarenessof newprocedures/productsand measuresto ensure the principlesof
validity and impartiality in decision-making during administrative appeals.
In this survey, exporters and importers were asked what customs procedures they undergo during
foreign trade and what difficulties they face while undergoing these procedures.
In particular, exporters reported on the following procedures:
(1) advance customsclearance;
(2) material andcommoditysampling;
(3) obtainingcertificatesof originforgoodsatcustoms;
(4) customsinspectionof goods;
(5) post-customsaudit(documentarychecksaftercustomsclearance).
Importers reported the following procedures:
(1) advance customsclearance;
(2) makingdecisionsonthe customsvalue of goods;
(3) makinga decisiononproductclassification;
(4) material andcommoditysampling;
(5) provisionof certificatesof originfor goodsduringcustomsclearance;
(6) customsinspectionof goods;
(7) post-customsaudit(documentarychecksaftercustomsclearance).
For eachprocedure,alistof difficultiesthatenterprisesparticipatinginforeigneconomicactivitymay
face was identified.
Businessesrarelyreportdifficultieswithcustomsprocedures,withthe exceptionof some procedures.
Importers face difficulties in customs procedures more often than exporters.
Classification of goods and deciding on their customs value are the most problematic customs
procedures for the surveyed enterprises.
Exportersoftenpointtothe complexityandlengthof the procedures,aswell asthe requirementsto
provide many documentsand the unreasonableness of some procedures (customs inspection,post-
audit).
Importers most often report unreasonable assignment of customs codes withhigher duty rates and
price increases, refusal to recognize the contract price of goods, different approaches to the same
legislation and the same goods, unreasonable procedures and their long duration.
Almost 2/3 of exporters did not face cargo delays compared to less than half of importers.

4. 4
Queues at the border remain the main reason for delays in exports and imports.
The success of business appeals against customs actions has deterioratedcompared to 2020, when
the share of companieswithfullyorpartiallysuccessfulappeal experience wasthe largestin4 waves
of the survey since 2016.
The level of awareness about the appeal procedure remains low: only half of the respondents are
familiar with it. Only one in five respondents has the experience of appealing.
The mostneededstepsare improvementof the validityof decisionsandensuringimpartial,complete
and fair consideration of the complaints.
Less than2% of respondentsare well aware of the new commontransit system(NCTS) andlessthan
14% are familiar with it by name. Most companies plan to use the NCTS once it is available
internationally, and about a third, in the near future.
The main advantage of the NCTS, according to the respondents, is the ability to travel to different
countrieswithone transitdocumentanda financial guarantee.The maindisadvantageisthe needto
obtain this guarantee.
Lessthan 7% of respondentsknow wellwhatanAEO is,and 10.6% are familiarwith it only by name.
The main advantages of the AEO are international recognition of this status, fewer documents and
lesswaitingtimeatthe border.The mainpotential problemisthecomplicatedprocedureforobtaining
this status.
Among digital products related to customs, respondents know best about the Single Window for
International Trade web portal, and the worst about the Business Intelligence module (BI, foreign
trade indicators on the State Customs Service website).

5. 5
1. Structure of the surveyed enterprises
The total number of foreign economic activity participating enterprises surveyedin 2021 was 1,006.
Among them there are microenterprises (46.6%), small (31.3%), medium-sized (14.9%) and large
(7.2%) enterprises.
Enterprises participatinginforeigneconomicactivitythattookpartinthe surveyare dividedintothree
groups according to the type of foreign economic activity:
 those that only export (25.2%) - hereinafter referred to as "exclusively exporters",
 those that only import (42.6%) – hereinafter referred to as "exclusively importers",
 enterprises engaged in both export and import (32.1%).
Surveyed enterprises operate in the agricultural, industrial, trade and service sectors (hereinafter
referred to as "services").
89% of businesses reported working with customs brokers.
The EuropeanUnionisthe mostcommonexportandimportdestinationforthe enterprisessurveyed.
67.6% of respondents were men, 32.4% were women.
2. Problems related to certain procedures
The enterprisesthattookpartinthe surveyreportedonwhatcustomsprocedurestheywentthrough
in their foreign economic activities and what difficulties they face in each of these procedures.
Exporters and importers reported on these procedures separately.
 Customs inspection is the most common procedure for exporters, despite the fact that it
should be carried out only on certain grounds. The next most common procedures are
obtaining certificates of origin and preliminary customs clearance.
Fig. 1. Shares of enterprises that underwent export procedures and encountered difficulties, %
 Difficulties with each procedure were experienced by 11% to 15% of exporters who
underwent these procedures.
 The most common procedures for importers are customs inspection and provision of
certificatesof originforgoods.Nextinprevalenceare decisionsonthe customsvalueof goods
and preliminary customs clearance.
44.7%
32.2%
56.8%
72.6%
17.2%
11.2% 11.8% 14.9% 12.4% 13.1%
0%
50%
100%
Advance customs
clearance
Material and
commodity sampling
Obtaining certificates
of origin for goods at
the customs
Customs inspection of
goods
Post-customs audit
Went through this procedure Faced difficulties during this procedure (among those that went through it)

6. 6
 Proceduresfordecidingonthe customs value of the goods and decidingonthe classification
of the goods cause the most difficulties for importers.
Fig. 2. Shares of enterprises that underwent import procedures and encountered difficulties, %
2.1. "Advance customs clearance" procedure
• The biggest problemat the stage of advance customs clearance, according to exporters,
is the significant duration of this procedure.
Fig. 3. Difficulties in the advance customs clearance procedure from the point of view of exporters, % of respondents who
reported difficulties
 The next most important problems are technical problems, in particular with computer
processing of documents and the complexity of this procedure.
 The two mainproblemsforimportersinadvance customs clearance are the inconsistencyof
Ukrainian and foreign documents and the considerable duration of this procedure.
 Importersmore oftenthanexporterspointtoinconsistenciesbetweenUkrainianandforeign
documents, while the problem of significant duration of advance customs clearance is
important for both exporters and importers.
69.4% 64.6% 69.3%
34.8%
74.9%
86.0%
22.1%
9.2%
38.1%
57.2%
24.0% 18.8% 17.9% 21.1%
0%
50%
100%
Advance
customs
clearance
Deciding on
classification of
goods
Deciding on
customs value
of goods
Material and
commodity
sampling
Provision of
certificates of
origin for goods
at customs
clearance
Customs
inspection of
goods
Post-customs
audit
Went through this procedure Faced difficulties during this procedure (among those that went through it)
3.6%
35.7%
35.7%
35.7%
46.4%
46.4%
53.6%
0% 20% 40% 60%
Other
Inconsistencies between Ukrainian and foreign documents
Corruption
Difficulties with pre-classification of goods
Procedure complexity
Technical issues, including computer processing of
documents
Significant duration of the procedure
From the point of view of exporters

7. 7
Fig. 4. Difficulties in advance customs clearance from the point of view of importers,% of respondents who reported difficulties
2.2. "Making decisions on product classification" procedure
Fig 5. Difficulties in the procedure for making a decision on product classification from the point of view of importers, % of
respondents who reported difficulties
6.7%
24.4%
28.9%
35.6%
37.8%
57.8%
60.0%
0% 20% 40% 60%
Other
Corruption
Technical issues, including computer processing of
documents
Procedure complexity
Difficulties with pre-classification of goods
Significant duration of the procedure
Inconsistencies between Ukrainian and foreign
documents
From the point of view of importers
2.2%
20.3%
33.0%
35.2%
38.5%
39.0%
42.9%
47.8%
57.7%
57.7%
62.1%
74.2%
0% 20% 40% 60% 80%
Other
Corruption
Lack of access to a single database of classification
solutions
Drawing up a report on violation of customs rules when
increasing the duty rate
Failure to take into account the basic rules of Ukrainian CN
FEA interpretation
Significant duration of procedure
Requirements to provide internal documents
Impossibility to predict the HS code in advance
Refusal of customs authorities to recognize the declared HS
code
Unequal classification of the same goods imported by
different importers
Requirements to provide a large number of additional
documents
Unreasonable determination of HS code with a higher duty
rate
From the point of view of importers

8. 8
 This procedure wasevaluated onlybyimporters.The mostcommon problemfromthe point
of view of importers is the unreasonable identificationof a product code with a higher duty
rate.
 The requirement of customs to provide a large number of additional documents is on the
second place among the problems with this procedure.
2.3. "Making decisions on the customs value of goods" procedure
 This procedure was evaluated only by importers. More than 70% of importers report
unreasonableincreasesinthe customsvalue of goodsandthe refusalof customstorecognize
the contract price of goods.
 More than 60% report non-transparent customs valuation of goods and requirements to
provide many documents.
Fig 6. Difficulties in the procedure for making decisions on the customs value of goods from the point of view of importers, %
of respondents who reported difficulties
2.0%
15.2%
20.6%
26.0%
41.9%
49.7%
50.0%
51.7%
55.7%
55.7%
57.1%
64.5%
67.2%
75.0%
77.0%
0% 20% 40% 60% 80%
Other
Inclusion of payments not performed by the enterprise
Corruption
Failure to take into account exchange rates and other
market factors
Significant duration of the procedure
Requirements to provide internal documents
Ignoring discounts for enterprises
Lack of access to the customs database
Manual control when making decisions about the
customs value
Determination of the price by the price of identical goods
Failure to predict the customs value in advance
Requirements to provide a large number of additional
documents
Nontransparent determination of the customs value
Customs refusal to recognize the contract price of the
imported goods
Unreasonable increase of the customs value
From the point of view of importers

9. 9
2.4. "Material and commodity sampling" procedure
 The main difficulties from the point of view of exporters are the considerable duration and
complexity of this procedure.
 Exporters report these problems more often than importers.
Fig 7. Difficulties in the procedure for sampling and samples of goods from the point of view of exporters, % of respondents
who reported difficulties
Fig 8. Difficulties in the procedure for sampling and samples of goods from the point of view of importers, % of respondents
who reported difficulties
4.8%
4.8%
14.3%
19.0%
19.0%
23.8%
42.9%
61.9%
71.4%
0% 20% 40% 60% 80%
Other
Violation of seals, which leads to problems with the
contractor
Use of laboratory test results for which it is impossible to
decide on the HS code
Different approach to the same legal requirements by
customs
Corruption
Carrying out laboratory tests of samples without
appropriate methods or equipment
Unreasonable carrying out of material and commodity
sampling procedure
Complexity of material and commodity sampling procedure
Significant duration of material and commodity sampling
procedure
From the point of view of exporters
13.3%
10.0%
13.3%
15.0%
28.3%
38.3%
41.7%
51.7%
56.7%
0% 20% 40% 60%
Other
Use of laboratory test results for which it is impossible to
decide on the HS code
Corruption
Violation of seals, which leads to problems with the
contractor
Carrying out laboratory tests of samples without
appropriate methods or equipment
Complexity of material and commodity sampling procedure
Different approach to the same legal requirements by
customs
Unreasonable carrying out of material and commodity
sampling procedure
Significant duration of material and commodity sampling
procedure
From the point of view of importers

10. 10
 The unreasonable carrying out of the material and commodity samplingprocedure occupies
the third place among the problems for exporters.
 The mainproblemforimportersisthe considerable durationof the material andcommodity
sampling procedure.
 Unreasonable carrying out of this procedure and a different approach to the same legal
requirements by customs are on the second and third places.
 Importers report the different approach to the same legislation by the customs more often
than exporters.
2.5. "Obtaining certificates of origin for goods at the customs" / "Providing
certificates of origin for goods during customs clearance" procedure
 Exporters evaluated the procedure "Obtaining certificates of origin for goods at customs."
Those who have encountereddifficultiesinthisprocedure mostoftenreportthe problemof
the requirement to provide many additional documents.
 The problemof the considerable durationof thisprocedure isonthe 2nd
place.
Fig 9. Difficulties in the procedure for obtaining certificates of origin for goods at customs from the point of view of exporters,
% of respondents who reported difficulties
 Importers most often report the problem of the customs’ requirements to provide many
additional documents.
 Half of importers report manual decision making when deciding on certificates of origin.
 The opacity of decision-making is on the third place among the problems during this
procedure.
8.3%
22.9%
41.7%
43.8%
54.2%
75.0%
0% 20% 40% 60% 80%
Other
Corruption
Nontransparent decision-making
Procedure complexity
Significant duration of the procedure
Requirements to provide a large number of additional
documents
From the point of view of exporters

11. 11
Fig 10. Difficulties in the procedure of granting certificates of origin for goods at customs clearance from the point of view of
importers, % of respondents who reported difficulties
2.6. "Customs inspection of goods" procedure
Fig 11. Difficulties in passing customs inspection of goods from the point of view of exporters, % of respondents who reported
difficulties
10.6%
11.7%
17.0%
35.1%
37.2%
38.3%
44.7%
51.1%
59.6%
0% 20% 40% 60% 80%
Other
Carrying out (as part of post-audit) of review of the facts of
certificate acceptance
Corruption
Unlawful refusals to accept the certificate of origin
Procedure complexity
Significant duration of the procedure
Nontransparent decision-making
Manual control when making decisions on certificates of
origin
Requirements to provide a large number of additional
documents
From the point of view of importers
4.2%
20.8%
25.0%
29.2%
33.3%
39.6%
41.7%
47.9%
54.2%
54.2%
64.6%
0% 20% 40% 60% 80%
Other
Imposing unreasonable fines or other punitive measures
Corruption
Multiple customs inspections of one foreign trade
operation
Initiating an inspection by law enforcement or regulatory
authorities
Damage to packaging of goods, deterioration of
appearance
Procedure complexity
Nontransparent decision-making
Unjustified customs inspection
Different approach to inspection of the same goods
imported by different importers
Significant duration of the procedure
From the point of view of exporters

12. 12
 The considerabledurationof the customsinspectionranksfirstamongthe problemswiththis
procedure from the point of view of exporters.
 The second place is shared by such problemsas unequal approach to inspection of identical
goods by different enterprises and unjustified customs inspection.
 The long duration of the customs inspection is the main problem for importers, too.
 The problem of unfounded customs inspection is on the second place for importers.
 The third andfourthplacesare occupiedbynon-transparentdecision-makinganddamage to
the packaging of goods and deterioration of their appearance.
Fig 12. Difficulties in passing customs inspection of goods from the point of view of importers, % of respondents who reported
difficulties
2.7. "Post-customs audit" procedure
 The complexityanddurationof thepost-auditprocedure are themainproblemsforexporters.
 Exporters report these problems more often than importers.
 The thirdplace isoccupiedbythe unreasonableincreaseinthe customsvalue of goodsatthe
stage of post-customs audit.
 The mainproblemwithpost-customsauditforimportersisthedifferentapproachtothe same
legal requirements by customs officers and auditors.
10.6%
13.3%
15.9%
21.2%
23.9%
31.9%
35.4%
40.7%
41.6%
44.2%
53.1%
0% 20% 40% 60% 80%
Other
Imposing unreasonable fines or other punitive measures
Initiating an inspection by law enforcement or regulatory
authorities
Multiple customs inspections of one foreign trade
operation
Corruption
Procedure complexity
Different approach to inspection of the same goods
imported by different importers
Damage to packaging of goods, deterioration of
appearance
Nontransparent decision-making
Unjustified customs inspection
Significant duration of the procedure
From the point of view of importers

13. 13
 For exporters,thisproblemisinthe lastplace inthe rankingandisreportedbyalmosthalf as
many exporters.
 The secondmost importantproblemfor importersischanges of the product code whenthe
declaration has been already issued.
Fig.13 Difficulties in the post-customs audit procedure from the point of view of exporters, % of respondents who reported
difficulties
Fig 14. Difficulties in the post-customs audit procedure from the point of view of importers, % of respondents who reported
difficulties
3. Cargo delays during customs control
 The resultsof the studyshowthatexportersface delayslessoftenthanimporters.Almost2/3
of exporters (62.4%) reported not experiencing cargo delays, compared to less than half of
importers (42.0%). At the same time, in 2020 the situation was similar - 59.6% of exporters
and 45.2% of importers.
30.8%
30.8%
38.5%
46.2%
61.5%
61.5%
0% 20% 40% 60% 80%
Different approach to the same legal requirements by
customs officers and auditors
Corruption
Change of HS code if the customs declaration already
issued
Unreasonable increase of the customs value at the audit
stage
Significant duration of the audit procedure
Audit procedure complexity
From the point of view of exporters
17.9%
14.3%
28.6%
39.3%
39.3%
53.6%
57.1%
0% 20% 40% 60% 80%
Other
Corruption
Audit procedure complexity
Significant duration of the audit procedure
Unreasonable increase of the customs value at the audit
stage
Change of HS code if the customs declaration already
issued
Different approach to the same legal requirements by
customs officers and auditors
From the point of view of importers

14. 14
 Queuesat the border remainthe maincause of delaysincustomscontrol forboth exporters
and importers.Thiswas reportedby67.5% of exportersand57.9% of importerswithdelays.
In2020, queuesatthe borderwere alsothe maincause of delaysincargo(69.8% of exporters
and 65.4% of importers).
 For exporters,importantreasonsfordelaysare alsothe lack of on-site inspectors,comments
on documents, and the lack of customs infrastructure. At the same time, it is important for
importers to change the customs value of goods, lack of inspectors and comments on
documents.
 The change inthe customsvalue of goodsasa reasonforthe delayof goods in 2021 and 2020
was onthe secondstep,butin 2021 itbecame evenmore relevant.If in2020 thisreasonwas
indicated by 26.9% of respondents who had delays, then in 2021 - 46.3%.
Fig 15. Share of enterprises without cargo delays, by size of enterprises, % of respondents
 In 2020, the results of the study showed that as the size of the enterprise increased,the
probabilityof delaysduringcustomscontroldecreased.Bigbusinesshasexperiencedtheleast
delaysatthe border.However,in2021 the situationhaschangedandmediumbusinessesare
experiencing the least delays.
Fig 16. Main reasons for the delay of Customs cargo during customs control during export, % of respondents with delays
58.0% 58.9%
74.6%
62.3%
42.5% 41.8% 45.7%
33.3%
-20%
30%
80%
Micro Small Medium Large
When exporting When importing
7.3%
10.2%
11.2%
12.6%
13.1%
13.6%
15.0%
19.4%
19.9%
67.5%
0% 20% 40% 60% 80%
Another option
Change in the customs commodity cost
Scanning, weighing of vehicles
Carrying out customs inspection at border
crossing points
Lack of all necessary documents
Corruption
Lack of customs infrastructure, equipment and
software
Notes to documents
Lack of inspectors
Queues at the border

15. 15
Fig 17. Main reasons for the delay of Customs cargo during customs control during import, % of respondents with delays
 By sector, the resultsare almostthe same for exporters.Atthe same time,importshave the
largest delays among representatives of the service sector.
4. Should businesses agree with unreasonable customs demands
to avoid downtime of goods?
 In 2021, businesseswere askedforthe secondtime whethertheyagreedwiththe statement
that inordertoavoiddowntime of goods,itisbettertoagree withillegalorexcessive,intheir
opinion, customs requirements than to challenge them legally.This questionwas first asked
in the 5th
wave of this survey in 2020.
 56.5% of the respondents agreed withthis statement. This is more than in 2020 (41%). This
suggests that lengthy and complicated customs procedures create an opportunity for
corruption and violations of the law.
 More than a thirdof respondents(38.3%) do not agree with this statement (48.2% in 2020).
 Onlyimportersandimportingandexportingcompaniesmore oftenthanonlyexportersagree
with this statement.
 Therefore, importers may be more vulnerable to the threat of downtime due to illegal or
excessive customs requirements.
 Micro and small enterprisesare more likelythanmediumandlarge enterprisestoagree with
this statement.
 The enterprisesthatcarry out customsclearance at the PivnichnaandOdesacustomsoffices
agree with this statement most often.
7.2%
8.8%
9.3%
10.9%
13.5%
19.8%
20.7%
21.6%
46.3%
57.9%
0% 10% 20% 30% 40% 50% 60% 70%
Lack of customs infrastructure, equipment
and software
Scanning, weighing of vehicles
IPR control
Lack of all necessary documents
Corruption
Carrying out customs inspection at border
crossing points
Notes to documents
Lack of inspectors
Change in the customs commodity cost
Queues at the border

16. 16
 Those whocarry outcustomsclearance at the Zakarpattia customs office agree most rarely.
Fig 18. Reaction to the statement that it is more expedient to agree with illegal or excessive customs requirements than to
challenge them legally, % of respondents
 The Zakarpattiacustomsoffice alsorecordedthe largestshare of respondentswhocouldnot
answer this question (10.3%).
 At Bukovyna customs office, all respondents answered this question.
Fig 19. Reaction to the statement that it is more expedient to agree with illegal or excessive customs requirements than to
challenge them legally, according to customs, % of respondents1
1 Answers of enterprises at the Azov and Skhidna Customs Offices arenot analyzed due to the insufficient
number of respondents.
10.8%
48.2%
41.0%
5.3%
38.3%
56.5%
0% 10% 20% 30% 40% 50% 60%
Don't know / Hard to say
Disagree
Agree
2021 2020
44.8%
51.1%
52.9%
54.5%
54.9%
57.0%
57.1%
57.7%
59.5%
61.9%
67.1%
68.2%
44.8%
42.9%
41.2%
40.9%
40.2%
38.4%
37.0%
38.5%
37.8%
38.1%
28.6%
27.3%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Zakarpattia
Halytska
Podilska
Chornomorska
Dniprovska
Slobozhanska
Kyiv
Poliska
Volyn
Bukovynska
Odesa
Pivnichna
Agree Disagree Don't know / Hard to say

17. 17
5. Appeals against the actions of customs authorities
 In 2021, 59.1% of respondents said theywere familiar with the possibility and procedure of
administrative and judicial appeals against the actionsof customs authorities. Thisis slightly
more than in 2020 - 53.5% of respondents, and in 2018 - 51.5%. Thus, the level of business
awareness of administrative appeals has increased slightly in recent years.
 In2021, 17.8% of respondentsreportedthattheyhadexperience appealing(in2020 - 18%, in
2018 - 15.9%). Thus, the situation has remained almost unchanged in recent years.
 Exporting and importing businesses, as well as large enterprises, remain more familiar with
the possibility of appeal and have more experience.
 Respondents at the Dnipro Customs (72.5%) are best acquainted with the possibility and
procedure of administrative or judicial appeal against customs actions, and the worst at the
Chornomorska Customs (40.9%).
 DniproCustomsenterprisesmostoftenhadanappeal (31.4%),andPivnichnaCustoms(9.1%)
the least.
Fig 20. Awareness and experience of appealing against the type of foreign economic activity, % of respondents
Fig 21. Awareness and experience of appealing by type and size of enterprises, % of respondents
52.8%
59.9% 63.2%
6.3%
20.0% 23.8%
0%
20%
40%
60%
80%
Exporters only Importers only Engaged in exporting and importing
Familiar with the appeal procedure Have experience of appeal
53.3%
65.4% 61.7%
68.1%
12.9%
17.6%
24.8%
33.3%
0%
20%
40%
60%
80%
Micro Small Medium Large
Familiar with the appeal procedure Have experience of appeal

18. 18
Fig 22. Awareness of Appeals and experience of Customs appeals, % of respondents2
 In 2021, appealsagainstcustomsactionswere partiallyorcompletelysuccessful for78.8%of
enterprisesthathadexperience of appeals.Atthe same time,in 2020 this figure was 87.8%.
This was the largest share for the first 4 waves of the survey since 2016.
 Accordingto the resultsof the study,the share of respondentswithunsuccessful experience
has increased more than one and a half times compared to 2020.
2 Answers of enterprises at the Azov and Skhidna Customs Offices arenot analyzed due to insufficientnumber
of respondents.
22.7%
9.1%
28.6%
13.5%
14.9%
21.4%
20.7%
13.5%
26.9%
23.5%
16.3%
31.4%
40.9%
45.5%
47.6%
55.6%
56.8%
58.6%
58.6%
59.5%
61.5%
61.8%
62.8%
72.5%
0% 10% 20% 30% 40% 50% 60% 70% 80%
Chornomorska
Pivnichna
Bukovynska
Halytska
Kyiv
Odesa
Zakarpattia
Volyn
Polissia
Podillia
Slobozhanska
Dnipro
Familiar with the appeal procedure Have experience of appeal

19. 19
Fig 23. Assessment of the success of administrative or judicial appeals against actions of customs authorities, % of enterprises
that had such experience3
 Only 55.3% of companies that challenged the actions of customs authorities indicated that
they were guaranteed the right to be heard (51.1% in 2020)
 Only 32.4% of enterprises that had experience in customs appeals consider the response of
the customs authority to the complaint justified (36.2% in 2020).
 32.7% of enterprises reported that they did not appeal against the actions of the customs
authorities due to economic inexpediency (due to simple transport, legal aid costs, etc.),
althoughtheyconsideredthe decisionsand/oractionsof the customsillegal(29.7% in 2020)
 Economicinexpediencyismore oftenreportedbyimportersandrepresentativesof the trade
sector.Atthe same time,large enterprisesmostoftenrefusedtoappeal,whichisthe opposite
of the situationin2020, whensucha refusal wasmostoftenreportedbysmallerenterprises.
 Most often, the actions of customs authorities were not appealed due to economic
inexpediency at Polissia and Dnipro Сustoms Offices. Rarely – at Bukovyna, Pivnichna and
Chornomorska Сustoms Offices.4
 Casesof economicinexpediencyof customsappeal are mostoftenreportedbyenterprisesof
the Poltava and Odesa regions. The least reported are in the Donetsk, Ternopil and Sumy
regions
 In nine regions, the share of enterprises that did not challenge the actions of customs
authorities due to economic inexpediency is a third or more of the respondents.
3 Another option, in particular,may includecomplaintsthatarestill beingconsidered.
4 The responses of enterprises at Eastern customs are not taken into accountin the analysisdueto the
insufficientnumber of respondents.
5.5%
20.4%
38.3%
35.8%
5.4%
14.9%
35.1%
44.7%
4.4%
20.1%
31.4%
44.0%
0.5%
11.7%
31.9%
55.9%
2.8%
18.4%
30.2%
48.6%
0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0%
Don’t know/ Another option
Was not successful
Was partially successful
Was completely successful
2021 2020 2018 2017 2016

20. 20
Fig 24. Share of enterprises that did not challenge the actions of customs authorities due to economic inexpediency, according
to customs, % of respondents
 The validityof decisions,andimpartial,complete andfairconsiderationof the complaintneed
to be improved the most.
 Only circa 10% of respondents believe that none of the aspects of the appeal needs to be
improved.
 SMEs more often than large enterprises point to the need for openness of complaints
consideration andimprovedvalidityof decisions(the same in2020). At the same time,large
enterprisesoftenexpressthe needforaquickand understandablerelease of goodsintofree
circulation. The situation has not changed compared to 2020.
16.7%
20.6%
11.6%
16.7%
21.4%
30.0%
23.7%
31.6%
24.4%
34.1%
41.7%
41.2%
23.8%
27.3%
27.3%
27.6%
29.4%
30.1%
32.4%
32.6%
33.7%
34.3%
40.2%
50.0%
0% 10% 20% 30% 40% 50% 60%
Bukovyna
Pivnichna
Chornomorska
Zakarpattia
Podillia
Halytska
Volyn
Kyiv
Slobozhanska
Odesa
Dnipro
Polissia
2021 2020

21. 21
Fig 25. Elements of administrative appeal implementation that need to be improved, % of respondents
6. Single Window
 Customs legislation foresees that all subjects of foreign economic activity, with rare
exceptions, pass customs procedures through the “single window” system.
 In2021, 18.7% of surveyedcompaniesreportedthattheypassedcustomscontrol throughthe
“single window”.
Fig 26. Experience in passing customs control measures through the "single window", % of respondents
2.0%
9.2%
42.2%
49.5%
53.4%
61.4%
64.4%
3.3%
11.4%
43.5%
54.9%
56.0%
62.9%
66.0%
0% 10% 20% 30% 40% 50% 60% 70%
Another option
None of these circumstances require improvement
Ensuring a quick and clear order of release of goods
into free circulation
Effectiveness of complaint consideration system in
electronic form
Openness of complaint consideration (opportunity to
participate in the complaint consideration)
Ensuring impartial, complete and fair complaint
consideration
Validity of decisions of the customs authority based on
the results of the complaint consideration
2021 2020
18.7%
9.1%
72.2%
Have experience of passing customs throughthe “one-stopwindow”
Don't have experience of passing customs throughthe “one-stopwindow”
Work with customs brokers / don't know / hard to answer

22. 22
 The majorityof the respondents(72.2%) workthroughcustoms brokersor could not answer
this question. This is more than in the previous waves of the survey.
 Excluding these respondents, the share of the enterprises that used the “single window” is
67.1%, which is much less than required by law.
Fig 27. Respondents who work through customs brokers or did not answer the question about the "single window", %
 Enterprisesthatare simultaneouslyexportersandimporters mostoftenreportthattheyhave
experience of passing customs procedures through the “single window”.
 The larger the size of enterprises, the more they use the “single window”: the share of the
enterprises operating through customs brokers decreases.
Fig 28. Experience of passing customs control measures through the “single window” by customs, % of respondents5
5 Responses of enterprises at the Azovska and Skhidna customs offices are not analyzed due to insufficient
number of respondents
54.0% 50.0%
69.0% 70.0% 72.2%
0%
20%
40%
60%
80%
100%
2016 2017 2018 2020 2021
10.8%
14.4%
17.2%
18.0%
18.6%
20.6%
22.5%
22.7%
23.1%
28.6%
30.2%
36.4%
2.7%
9.8%
10.3%
8.3%
12.9%
8.8%
4.9%
13.6%
19.2%
4.8%
11.6%
86.5%
75.8%
72.4%
73.7%
68.6%
70.6%
72.5%
63.6%
57.7%
66.7%
58.1%
63.6%
0% 20% 40% 60% 80% 100%
Volyn
Kyiv
Zakarpattia
Halytska
Odesa
Podilska
Dniprovska
Pivnichna
Poliska
Bukovynska
Slobozhanska
Chornomorska
Have experience Don't have experience Other options

23. 23
 Enterprisesat the Chornomorska,SlobozhanskaandBukovynskacustomsofficesreportthat
theyhave experienceof passingcustomsproceduresthroughthe“single window“ mostoften.
 Enterprisesatthe Volyncustomsofficeare the leastlikelytoreportsuchanexperience.There
is the largest share of respondentswho work through customs brokers or could not answer
here (86.5%).
 At Poliska, Pivnichna and Odesa customs, businesses report that they do not have such
experience most often.
7. New computerized transit system (NCTS)
 National applicationof the NCTSinUkraine beganinMarch 2021.
 Only1.6% of respondentsknow whatthe new computerizedtransitsystem(NCTS) is.The
majority(85%) do notknowabout itand another13.4% know itonlyby name.
Fig 29. Respondents' awareness about the NCTS, %
 The share of the respondentswhoknow well aboutNCTS isvery small among enterprisesof
different sizes, sectors and types of foreign trade.
 Against the background of others, only large enterprises and enterprises with import and
export differ. Their representatives know about NCTS by name more often than others. This
indicates possible gaps in communication regarding this possibility.
 This may also be related to working through customs brokers. Representatives of the
companiesnotworkingwithbrokersare more likelytoknow aboutthe NCTSwell orbyname
(27.3% compared to 13.5% of the representatives of those working with brokers).
 No company whose representatives know about the NCTS well usedthis system at the time
of the survey6
.
6 The analysisof the responses was conducted on a small sample(N= 16) of the respondents who said thatthey
know well or fairly well about the NCTS.
18.7%
9.1%
72.2%
Know well or well enough
Know only by name
Don't know what NCTS is / Hard to say

24. 24
Fig 30. Plans about using the NCTS, %
 Most companies (43.8%) planned to use the NCTS after it started operating internationally.
About a third of enterprises (31.3%) planned to start using the NCTS in the near future.
 Equal sharesof the respondents(12.5% each) indicatedthattheydonotplantouse the NCTS
and did not answer this question.
Fig 31. Advantages of the NCTS according to the respondents who know about it well or well enough, % of respondents
 Respondentswhoare well orfairlyfamiliarwiththe NCTSoftennameitsalmosteverybenefit.
The main advantage is the ability to pass through different countries with one transit
document and a financial guarantee7
.
 The leastimportantadvantage of the NCTSisthe reductionof the costof customsprocedures
(33.3%).
7 The analysisof the responses was conducted on a small sample(N= 16) of the respondents who said thatthey
know well or fairly well about the NCTS.
31.3%
43.8%
12.5%
12.5%
Plan to start using NCTS in the near future, when it is still working
nationally
They plan to use NCTS only when it works internationally
Do not plan to use this system
Don't know / Hard to say
33.3%
60.0%
66.7%
66.7%
66.7%
80.0%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Cheaper customs procedures
Reducing the pressure of customs authorities on business
Simplification of customs procedures
Better traceability of goods
Reducing corruption at customs
Ability to travel to different countries with one transit
document and a financial guarantee

25. 25
 The respondentswhoare wellorfairlyfamiliarwiththeNCTSoftencitethe needforafinancial
guarantee for all NCTS transit movements as a major disadvantage of the NCTS.
Fig 32. Disadvantages of the NCTS system according to respondents who know well or fairly well about it, % of respondents
Fig 33. What information about NCTS is lacking, %
 The smallest share of the businesses voiced reservations about the adaptation to the new
rules.Andapproximatelyone infourrespondentsbelievesthatthere are no shortcomingsin
the NCTS.
 The respondentswhoknowthe NCTSwelloronlybyname are ofteninterestedinwhenitwill
be implemented and what are its benefits for their companies.
 The third place among the issues on which there is a lack of information is occupied by the
question whether the NCTS will require additional investment for businesses.
 Almosta thirdof the respondentsindicatedthattheyhave enoughinformation about NCTS.
28.6%
14.3%
14.3%
28.6%
35.7%
57.1%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
There are no shortcomings in the NCTS
Other disadvantages
Businesses will find it difficult to adapt to the new rules
Significant monetary expenditures of enterprises
Need for additional documents
Need for a financial guarantee for all transit movements
under the NCTS
32.6%
0.7%
33.3%
37.7%
38.4%
39.9%
40.6%
46.4%
48.6%
50.0%
0% 20% 40% 60%
Respondents have enough information about the NCTS
Other information
What will change regarding the provision of financial
guarantees
How customs procedures will change with the transition to
this system
Whether their company will be able to use the system
What are the requirements for companies that want to use
this system
How a company can join the system
Whether it will require additional investment, staff
expansion etc.
What benefits the company will obtain from this system
When this system will be implemented in Ukraine

26. 26
8. AEO status
 More than 80% of respondents do not know what the status of the Authorized Economic
Operator (AEO) is. Only 6.8% know well or well enough what it is. Every tenth respondent
(10.6%) knows about it only by name.
 Thisindicatesprobablegapsincommunicationregardingthe AEO,despitethe factthatatthe
time of the survey the enterprises already had the opportunity to register as AEOs.
Fig 34. Awareness about the AEO status, %
 Representatives of companies that are both exporting and importing know about the AEOs
best.
 Representatives of large enterprises know about AEOs three times more often than
respondents from medium-sizedbusinesses, and ten times more often than representatives
of micro-enterprises.
 Amongthe representativesof enterprisesof differentsectors, thoseinthe trade sectorknow
about the AEO the least.
 Respondents in Ivano-Frankivsk and Volyn oblasts are best informed about the AEO status.
Every tenth respondent in Ternopil, Vinnytsia and Donetsk oblasts is well aware of AEO.
 None of the respondents in Cherkasyand Sumy oblasts indicated that they knew well about
the AEO status.
 The largest share of respondents who do not know about the AEOs at all is in Rivne oblast
(91.7%).
6.8%
10.6%
82.4%
0.2%
Know well or well enough Know only by name
Do not know what an AEO is Didn't answer / Hard to say

27. 27
Fig 35. Awareness about the AEO by region8, %
Fig 36. Desire to obtain the AEO status, %
8 Respondents' responses in Luhansk and Mykolaiv oblasts are not taken into account in the analysis due to
insufficient number of respondents
3.7%
4.0%
4.2%
4.9%
5.0%
5.0%
5.3%
5.3%
5.3%
5.5%
6.5%
6.5%
6.6%
7.4%
8.0%
8.3%
9.5%
10.0%
10.0%
11.1%
12.0%
11.1%
20.8%
11.1%
16.0%
8.3%
9.8%
5.0%
10.0%
5.3%
10.5%
15.8%
10.5%
6.5%
7.8%
13.2%
22.2%
5.3%
4.8%
10.0%
25.0%
14.8%
12.0%
88.9%
79.2%
85.2%
80.0%
87.5%
85.3%
90.0%
85.0%
89.5%
84.2%
78.9%
84.0%
87.0%
85.7%
80.2%
70.4%
86.7%
91.7%
85.7%
80.0%
65.0%
74.1%
76.0%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Cherkasy
Sumy
Zhytomyr
Chernihiv
Poltava
Kyiv oblast
Chernivtsi
Khmelnytsky
Kirovohrad
Kherson
Zaporizhzhya
Kyiv city
Odesa
Lviv
Kharkiv
Zakarpattia
Dnipropetrovsk
Rivne
Donetsk
Vinnytsia
Ternopil
Volyn
Ivano-Frankivsk
Know well or well enough Know only by name Don't know or hard to say
4.4%
2.9%
52.9%
14.7%
20.6%
4.4%
The company already has the AEO status
The company is in the process of obtaining the AEO status
The company would like to obtain the AEO status
The company would like to obtain the AEO status, but does not meet the requirements
The company would not like to obtain the AEO status
Don't know / Hard to say

28. 28
 More than half of the companieswhose representativesknow wellaboutthe AEOwouldlike
to receive this status. Almost 3% (2 companies) are in the process of obtaining it and 3
companies claimtohave this status, despite the fact that they are not in the AEOs register.
 Almost 15% said they would like to receive this status, but do not meet the requirements.
 One infive companies(20.6%) doesnotwanttoreceive the AEOstatus.The mainreasonwhy
they do not want to receive this status is because they do not think they need it.
 Other frequently mentioned reasons for not wanting to become AEOs are the expectations
that the financial costs of obtaining the AEO status may exceed its benefits, that this will
require the disclosureof confidentialinformationaboutthecompany,andthatthe AEOstatus
will not simplify customs procedures.
Fig 37. Advantages of the AEO status according to respondents who know well or fairly well about it, %
Fig 38. Potential problems with obtaining the AEO status according to respondents who know it well or well enough, %
 Respondents who know about the AEO well or fairly well name its following three main
advantages most often: recognition of the AEO status of a Ukrainian enterprise by other
countries in the future, reduction of the number of documents required for customs
procedures, and reduction of waiting time at the border (70,1% of respondents per each).
10.4%
1.5%
46.3%
49.3%
59.7%
70.1%
70.1%
70.1%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
There are no advantages in the AEO status
Other advantages
Reducing corruption at customs
Reducing the pressure of customs authorities on
business
Greater predictability of customs procedures
Reducing waiting times at the border
Reducing the volume of documents for customs
procedures
Recognition of Ukrainian AEO status by other countries
in the future
17.5%
6.3%
20.6%
27.0%
31.7%
55.6%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Do not expect problems with obtaining the AEO status
Other problems
Significant financial costs for obtaining this status
It will be difficult for companies to meet the
requirements
Lack of necessary information about obtaining the AEO
status
The complicated procedure for obtaining this status

29. 29
 Approximately one in ten respondents(10.4%) believes that there are no advantages in the
status of the AEO.
 Respondentswhoare wellorfairlyfamiliarwiththe AEOoftenbelievethatpossible problems
withobtainingthe AEOstatus may arise due to the complicatedprocedure forobtainingthis
status (55.6%).
 Abouta third of respondents(31.7%) name the lack of informationaboutobtainingthe AEO
status among the potential issues.
 17.5% of respondents do not expect any problems with obtaining the AEO status.
 RespondentswhoknowaboutAEOwell oronlybynamemostoftensaythattheyhaveenough
information about it (43%).
 The information that is often lacking is:
- when the AEO will be introduced in Ukraine;
- how an enterprise can obtain this status;
- whetherthe acquisitionof AEOstatus will require additional investment,staff expansion,
etc. from the enterprises.
Fig 39. What information about AEO the respondents lack, %
9. Digital products
 Representatives of the enterprises reported whether they are aware of digital products
related to customs and whether they use these products. In particular, they gave answers
regarding the following products:
- Unified government information web portal “Single Window for International Trade”
located on the website of the State Customs Service https://cabinet.customs.gov.ua
43.0%
0.6%
24.2%
30.9%
32.7%
32.7%
33.9%
37.0%
38.2%
40.0%
0% 10% 20% 30% 40% 50%
The information about the AEO is enough
Other information
What the AEO status gives for the company
How customs procedures will change for enterprises with
the AEO status
Whether their company meets the criteria for this status
What are the requirements for companies to obtain the
status of AEO
What benefits will the company receive from the AEO
status
Whether this will require investment, staff expansion etc.
How a company can obtain this status
When the AEO will be introduced in Ukraine

30. 30
- Personal account on the web portal “Single Window for International Trade” on the
website of the State Customs Service https://cabinet.customs.gov.ua/login
- The QD Professional (QD Pro) or MD Declaration platform
- Foreign trade indicators on the website of the State Customs Service
https://bi.customs.gov.ua(the BusinessIntelligence interactive import-exportoperations
analytics module)
- The online map of the infrastructure of Customs Service facilities on the State Customs
Service website https://map.customs.gov.ua/
 Most respondentsknowaboutthe “SingleWindowforInternational Trade”webportal (42%).
Fewer respondents (37.1%) know about a personal cabinet on this portal.
 However,onlyeverytenth respondentusesthisportal withoutauthorization(9.7%) andwith
authorization (10.5%).
Fig 40. Awareness of and use of digital products, %
 QD Pro and MD Declaration platforms are the only digital products where the share of the
respondentswhoknowaboutthemand use themis higherthan the share of those whojust
know about them.
 The share of the respondents whoknow aboutthe BusinessIntelligence module anduse itis
the smallest.
0.3%
0.6%
1.2%
1.2%
1.3%
67.2%
73.3%
64.5%
61.7%
56.7%
24.5%
20.4%
14.1%
26.5%
32.3%
8.1%
5.8%
20.2%
10.5%
9.7%
0% 10% 20% 30% 40% 50% 60% 70% 80%
Online map of the infrastructure of customs facilities on
the website of the State Customs Service
Business Intelligence (foreign trade statistics on the
website of the State Customs Service)
QD Pro or MD Declaration platforms
Personal cabinet at the "Single Window for International
Trade" on the website of the State Customs Service (with
authorization)
"Single Window for International Trade" on the website
of the State Customs Service (without authorization)
Awareness of and use of digital products,%
Know and use Know but don't use Don't know about them Hard to say

31. 31
Survey methodology
Businesses engaged in foreign trade – import and export – face its conditions, advantages and
disadvantages basedon their own experience. Therefore, in order to study the existing problems in
this area and identify the reformsand policysteps needed to solve them, it is important to hear the
opinion of these businesses.
Tothisend,the InstituteforEconomicResearchandPolicyConsulting(IER) regularlyconductsnational
monitoringof businessopinionthroughanannual surveyof more than1,000exportersandimporters.
Such a surveymakesitpossible toreceive “feedback”directlyfrombusinessrepresentativesandfind
outwhat obstaclestheyface intheirwork,whatchangestheyneed,andhow theyrespondtovarious
innovations.
In 2015-2016, the IER conductedsuchmonitoringforthe firsttime withinthe frameworkof the Trade
FacilitationDialogue project.Thiswave of the surveywas experimental andexploratoryandcovered
381 enterprises engagedin foreign trade. The field stage of information gathering was held in April-
August2015. In the followingyears,withinthe frameworkof the Trade FacilitationDialogue project,
the IER conducted four more waves of this monitoring:
 The second wave of the monitoring was carried out in 2016-2017. The information was
gathered in October-December 2016. 1,044 enterprisesparticipating in foreign trade were
interviewed.
 The thirdwave of the monitoringwascarriedoutin2017-2018. The informationwasgathered
in November 2017 – February 2018. 1,019 enterprises participating in foreign trade were
interviewed.
 The fourth wave of the monitoring was carried out in 2018-2019. The information was
gathered in October-December 2018. 1,012 enterprisesparticipating in foreign trade were
interviewed.
 The fifth wave of the monitoring was carried out in 2020. The information was gathered in
April-June 2020. 1,045 enterprises participating in foreign trade were interviewed.
The sixth wave of this survey was held in 2021 as a part of the “Public Initiative “For Fair and
Transparent Customs” project. The field stage of the surveywas held from May 26 to September 8,
2021. 1,006 enterprises participating in foreign trade were interviewed.
Fieldstagesof the second,thirdand fourthwavesof the surveywere conductedbyGfK Ukraine,and
fieldstagesof the fifthwave in2020 and the sixthwave in 2021 were conductedby the InfoSapiens
Research Agency. Samples from the second, third, fourth, fifth, and sixth waves of the survey are
representative in the national dimension.
2021 surveywasconductedusingaquantitativetelephonesurveyusingacomputer(CATI –computer
assistedtelephone interviews).Allinterviewswereconductedwithrepresentativesof enterprisewho
can assessthe economicsituationof the enterprise andthe conditionsforcarrying out foreigntrade
(owners,directors,deputydirectors,chief accountants,headsof the departmentordeputyheadsof
the department related to the implementation of export or import).
Enterprisesfromall over Ukraine took part in the survey,withthe exceptionof those locatedonthe
territory of the temporarilyoccupied AutonomousRepublic of Crimea and the city of Sevastopol,as
well ascertainregionsof Donetskand Luhanskregionsthatare not controlledbythe Governmentof
Ukraine.

32. 32
At the data analysisstage,the numberof observationsforeach sample parameterwascontrolled.If
the number of observations was insufficient for statistical analysis, such analysis was not performed
and, accordingly, is not provided in the report.
To conduct monitoring, the IER has developed a standardized questionnaire for interviewing
enterprises. This report compares the results of the surveys of different waves on a number of
questions,the wordingof whichinthe sixthwave of the surveydidnotchange comparedtoprevious
wavesof the survey.Atthe same time,some questionsare alsocomparedwiththe resultsof the first
wave of the survey in 2015-2016. However, it should be taken into account that the sample of this
wave of the survey was different from the subsequent ones, which may affect the difference in
indicators.
Distribution of respondents by region
The survey was conducted in all regions of Ukraine, with the exception of the temporarily occupied
AutonomousRepublicof Crimeaandthe cityof Sevastopol,aswell ascertaindistrictsof Donetskand
Luhanskregions.Ineachregion,from8(Luhanskregion) to181 (Kyivcity) enterprisestookpartinthe
survey.
Table 1. Distribution of surveyed enterprises by region
Number of businesses Percentage of the sample
Vinnytsia 30 3,0%
Volyn 27 2,7%
Dnipropetrovsk 75 7,5%
Donetsk 21 2,1%
Zhytomyr 27 2,7%
Zakarpattia 27 2,7%
Zaporizhzhia 38 3,8%
Ivano-Frankivsk 25 2,5%
Kyiv 102 10,1%
Kirovohrad 19 1,9%
Luhansk 8 0,8%
Lviv 77 7,7%
Mykolayiv 9 0,9%
Odessa 46 4,6%
Poltava 24 2,4%
Rivne 24 2,4%
Sumy 24 2,4%
Ternopil 20 2,0%
Kharkiv 91 9,0%

33. 33
Number of businesses Percentage of the sample
Kherson 19 1,9%
Khmelnytsk 20 2,0%
Cherkassy 27 2,7%
Chernivtsi 20 2,0%
Chernihiv 25 2,5%
Kyiv city 181 18,0%
Total amount 1006 100%
Distribution of respondents by customs
To assesscustomsprocedurescarriedoutbybusinessesatthe customsoffices,the respondentswere
asked to indicate at which customs office they mainly carry out processing of their goods. For this
purpose,the classificationof customsofficesof 2019wasused,when16customsofficeswereformed
in the structure of the State Customs Service, including 14 regional customs offices, as well as the
Energy Customs and Coordinationand Monitoring Customs. Since the assessment in the survey was
made for the previousyear,duringwhichthisstructure wasstill ineffect,we use thisclassificationto
make comparisons for some indicators.
The largestshare of the surveyedenterprises(368 or 36.6% of the total sample) carriesoutcustoms
clearance at the Kyiv customs office, which united Zhytomyr, Kyiv, Kyiv city and Cherkasy customs
officesof the State Fiscal Service.The nextlargestshare of respondents(133enterprisessurveyedor
13.2% of the sample) carries out customs clearance at the Halytska customs, where three customs
offices were combined: Ivano-Frankivsk, Lviv, and Ternopil.
Dniprocustoms(102 surveyedenterprises,whichisalmost10.1% of the total numberof respondents)
and Slobozhanskacustoms(86enterprisesor8.5% of the sample) are inthe thirdandfourthplacesin
terms of the largestnumberof enterprisesthatcarry out customsclearance there.Servicesof other
customs offices are used by a smaller proportion of the surveyed enterprises. In addition, 36
enterprisesdid not name the customs where they carry out customs clearance. They made up 3.6%
of the sample.
Table 2. Distribution of the surveyed enterprises by customs, where they mainly process goods
Number of
businesses
Percentage of the
sample
Azovska customs (Donetskcustoms of the State
Fiscal Service of Ukraine)
12 1,2%
Bukovynska customs (Chernivtsi customsof
SFS)
21 2,1%
Volynskacustoms (Volyncustoms of SFS) 37 3,7%
Halytska customs (Ivano-Frankivskcustomsof
SFS, Lviv customs of SFS,Ternopil customs of
SFS)
133 13,2%

34. 34
Number of
businesses
Percentage of the
sample
Dniprovska customs (Dnipropetrovskcustoms
of SFS, Zaporizhzhiacustoms of SFS,Kirovohrad
customs of SFS, Poltava customs ofSFS)
102 10,1%
Zakarpatska customs (Transcarpathian customs
of SFS)
29 2,9%
Kyyivska customs (Zhytomyr customs ofSFS,
Kyiv customs of SFS,Kyiv city customs of SFS,
Cherkassy customsof SFS)
368 36,6%
Odeska customs (Odessacustoms ofSFS) 70 7,0%
Pivnichnacustoms (Chernihivcustomsof SFS) 22 2,2%
Podilskacustoms (Vinnytsiacustoms of SFS,
Khmelnitskyi customsof SFS)
34 3,4%
Poliskacustoms (Rivne customs of SFS) 26 2,6%
Slobozhanskacustoms (Sumy customs of SFS,
Kharkiv customs of SFS)
86 8,5%
Skhidna customs (Luhansk customs ofSFS) 8 0,8%
Chornomorska customs (Mykolaivcustoms of
SFS, customs of the State Fiscal Service inthe
Khersonregion,the Autonomous Republicof
Crimeaand the city ofSevastopol
22 2,2%
Did not specifycustoms 36 3,6%
Total amount 1006 100%
Customs posts where businesses carry out registration
The majority of enterprises (610 enterprises) indicated a customs post where they mainlycarry out
customsclearance.The customspost,whichwasmostoftencalledbythe surveyedenterprises,isKyiv
airport,locatedat the International AirportKyiv(Zhuliany).146 enterprisesare surveyedhere,which
is 14.5% of the sample.
More than 20 enterprisescarryout customsclearance atthe customspostsYavoriv,Konstiantynivka,
Zaliznychnyi,Odessa-airport,YahodynandPivdennyi.396 enterprisesor39.4% of the sample didnot
name the post where they carry out customs clearance.
Table 3. Distribution of surveyed enterprises by customs posts, where they mainlymake out the goods
Number of
businesses
Percentage of the
sample
Kyiv airport customs post 146 14,5%
Yavoriv customs post 43 4,3%
Kostiantynivka customs post 37 3,7%
Zaliznychnyi customs post 37 3,7%
Odessa-airportcustoms post 30 3,0%

35. 35
Number of
businesses
Percentage of the
sample
Yahodyn customs post 30 3,0%
Pivdennyi customspost 20 2,0%
Chop-Zaliznychnyi customspost 16 1,6%
Mostyska-Zaliznychnyi customspost 14 1,4%
Zaporizhzhia-airportcustoms post 13 1,3%
Spetsializovanyi customspost 12 1,2%
Prykarpattia customs post 12 1,2%
Sumy customs post 12 1,2%
Zhytomyr-Tsentralnyi customs post 12 1,2%
Chernivtsi customspost 10 1,0%
Vinnytsiacustoms post 9 0,9%
Boryspil customspost 9 0,9%
Shcherbakivka customs post 8 0,8%
Rava-Ruska customs post 8 0,8%
Mostyska customs post 8 0,8%
Diakovo-avtomobilnyi customspost 7 0,7%
Poltava customs post 7 0,7%
Kharkiv Airport customs post 7 0,7%
Kovel customs post 7 0,7%
Uzhhorod-avtomobilnyi customspost 7 0,7%
Cherkassy-Tsentralnyi customspost 6 0,6%
Khersoncustoms post 5 0,5%
Rivne customs post 5 0,5%
Korosten customspost 5 0,5%
Bilhorod-Dnistrovskyi customspost 5 0,5%
Kryvyi Rih customs post 5 0,5%
Novi Yarylovychi customs post 5 0,5%
Zakhidnyi customs post of the energycustoms
of the State CustomsService
5 0,5%
Kostiantynivka customs post 4 0,4%
Stolychnyi customs 4 0,4%
Izmail customs post 4 0,4%
Chernihivcustomspost 4 0,4%

36. 36
Number of
businesses
Percentage of the
sample
Berdiansk customs post 3 0,3%
Khersoncustoms post 3 0,3%
Sarny customspost 3 0,3%
Mariupol-portcustoms post 3 0,3%
Odessa-vnutrishnii customspost 3 0,3%
Dnipro-Buzskyi customs post 2 0,2%
Dnister customs post 2 0,2%
Luzhanka customspost 2 0,2%
Reni customs post 2 0,2%
Tysa customs post 1 0,1%
Druzhba customs post 1 0,1%
Ovruch customs post 1 0,1%
Dolsk customs post 1 0,1%
Domanove customs post 1 0,1%
Uhrynivcustoms post 1 0,1%
Vadul-Siretcustomspost 1 0.1
Mamalyha customs post 1 0.1
Starokozache customs post 1 0.1
Didn'tspecifya customs post 396 39,4%
Total amount 1006 100%