The Solar Energy Association of Ukraine (SEAU) has received an official response to its appeal to the Cabinet of Ministers of Ukraine dated January 13, 2026, regarding the need to ensure the uninterrupted supply of critically important goods to Ukraine.
At the end of 2025, the Cabinet of Ministers of Ukraine adopted Resolution No. 1795 of December 31, 2025, approving the list of goods subject to import and export licensing in 2026. In particular, Annex 3 included electric lithium-ion batteries, including separators, which caused significant complications for the energy market from the very first days of the new year.
Given the critical role of battery systems and energy storage installations for the country’s energy security – especially under martial law – the Solar Energy Association of Ukraine officially submitted a letter to the Cabinet of Ministers of Ukraine in early January 2026, highlighting the risks and negative consequences of the introduced regulation.
In its appeal, SEAU emphasized that under paragraph 3 of CMU Resolution No. 1795, only goods containing controlled substances are subject to licensing, namely:
- ozone-depleting substances (ODS);
- fluorinated greenhouse gases (F-gases).
At the same time, the mere fact that a product is a battery or a battery system does not automatically require a license if such substances are not actually present.
Most modern lithium-ion batteries contain neither ODS nor F-gases; however, due to their formal inclusion in the list based on UCGFEA (HS) codes, imports were effectively blocked and customs procedures excessively complicated.
SEAU also noted that although state regulation of hazardous substances is предусмотрено under the Law of Ukraine “On Environmental Protection” and has existed previously, the new version of the lists created disproportionate administrative pressure on businesses and posed a threat to the uninterrupted supply of critically important equipment.
As a result of the Government’s consideration of this issue, CMU Resolution No. 102 of January 29, 2026 was adopted, removing electric lithium-ion batteries, including separators, from the list of goods subject to licensing. However, importers are advised that charged fire extinguishers (HS code 8424 10 00) remain on the list.
The Solar Energy Association of Ukraine welcomes this decision as an important step toward restoring the balance between environmental regulation and energy security needs, as well as an example of constructive dialogue between the state and the professional community.
SEAU will continue to consistently advocate for the interests of solar energy sector participants and contribute to the development of effective, predictable, and well-grounded regulatory policies for renewable energy.