The Ukrainian Agri Council calls for amendments to or cancellation of the Order of the Odesa Regional State (Military) Administration "On Some Issues of Financial Discipline under the Legal Regime of Martial Law" No. 19 as of August 18, 2023.

The UAC was approached by agricultural producers who were denied customs clearance based on the provisions of this order. Another part of farmers and traders report that they have stopped applying to Odesa Customs altogether due to the inability to comply with the terms of this order.

The provisions of the document require exporters to file a customs declaration 10 days before loading a vessel. To fill it out, the seller must prepare the necessary volume and accumulate grain in the port, and be sure that the vessel will receive the grain of the volume and quality specified in the declaration. The cost of the consignment will depend on these indicators. In practice, it is not possible for most farmers to fulfill these conditions.

Today, producers and traders do not accumulate grain in ports in order not to expose people, infrastructure and goods to the danger of shelling by Russia. That is why most sellers are now working from the "wheels" - loading the ship is mostly done directly from the truck to the ship. Moreover, the ports on the Danube do not have enough storage space to store such volumes of grain that are subject to pre-declaration.

Please note that the provisions of the Order are advisory and not binding on business entities. However, the UAC receives signals that the Odesa Customs has taken the preliminary declaration of goods as a basis and requires it.

By this order, the Odesa Customs hinders the export capabilities of sea and river ports, which is unacceptable in the context of constant shelling and blocked traditional logistics routes by the Russian Federation.

The UAC understands that the fight against illegal turnover of grain must be mandatory, but this process should not harm bona fide exports, especially in times of war. Today, farmers are already experiencing excessive bureaucratic pressure at all stages - from production to export. Another regulatory mechanism from the Odesa Regional State (Military) Administration to those already in place under laws and regulations is excessive and unreasonable.

We hope that the opinion of the business will be heard and the Odesa Regional State Administration will amend or cancel its Order No. 19 as of August 18, 2023.