The State Tax Service has changed the approach to calculating excise stamp limits for tobacco manufacturers and importers

Ukraine has clarified the procedure for calculating excise stamp limits for enterprises that simultaneously produce and import tobacco products. From now on, the total production and import indicators will be taken into account when determining the allowable volume of stamps. The new approach will be applied already in October-December 2026.

Why the changes were necessary

The reason for revising the approach was Russian attacks on production facilities and warehouses of tobacco companies.

Due to damage to enterprises, some manufacturers are forced to switch to importing finished products in order to ensure the continuity of supplies of goods to the Ukrainian market.

At the same time, the previous approach to determining limits could create difficulties for such companies. In particular, if the enterprise previously mainly produced products in Ukraine, the volumes of its imports were insignificant, which affected the calculation of the allowable number of excise stamps.

How the limits will now be calculated

According to the State Tax Service’s clarification, during the three months before the increase in excise tax rates, the sale of excise stamps is limited to 120% of the average monthly sales volume of products for the previous nine months.

Since the next rate increase is scheduled for January 1, 2027, the corresponding restrictions are in effect from October to December 2026.

For enterprises that simultaneously produce and import tobacco products, the limit will be determined taking into account the total sales volume of products of the same type.

The calculation is carried out separately for:

cigarettes;

electrically heated tobacco products (HETP);

tobacco.

In this case, the total sales volume for the previous period is divided by nine months, even if the enterprise did not make sales during certain months.

When to file a declaration

The first declaration using the new approach must be filed by enterprises for October 2026.

The deadline for submission is November 20, 2026.

The State Tax Service emphasizes that the relevant clarification is of an informational nature and does not constitute individual tax advice.

What does this mean for business

The clarified procedure allows importers to take into account the actual sales volumes of tobacco products, regardless of whether they were manufactured in Ukraine or imported from abroad.

This is especially relevant for enterprises that, due to the consequences of Russian shelling, were forced to change the product supply model.

At the same time, companies need to correctly determine sales volumes for the previous nine months and adhere to the established deadlines for reporting.