At the last export office, the Association "Ukrkondprom" appealed to Ukrzaliznytsia for help. After all, many trucks with confectionery products got stuck at the borders because they were blocked by the Poles. Were they able to help you at UZ??

Ukrzaliznytsia did not help us much, although they sincerely tried, but this is how they work with the export of fast-moving consumer goods (consumer goods, — line.). Conceptual approaches, which UZ applies to the organization of cargo transportation, not very suitable for finished products. Suitable for raw materials. But they are them, of course, extrapolated to finished products.

And what exactly is the problem? Conditions, regulations, lack of rolling stock? 

The conditions are standard. And they are used for all types of products. The problem is that, that metal rolling can afford to "ride" around Ukraine for several weeks. Or go 300-400 km all week, although this distance can be covered in a day or two. Confectionery products, for example, the same chocolate, it is not desirable to transport like this. We need to know clearly the terms of delivery. And UZ cannot deliver in clear terms.

That is, UZ cannot give a guarantee, that will quickly and on time transport your products from point A to point B?

So, I can not say, that they did not try to help us during the meeting with the representatives of the University. We were looking for some options, but that, what they offer, does not make our exports too easy. You can talk a lot, but eventually we come down to simple numbers, which tell about the specific weight of transportation costs in the cost of products. We see, that according to this indicator, we are losing competitiveness with EU goods. Therefore, there are many questions regarding the operation of the UZ system itself: to the price, to the quality of transportation, to meet the deadlines. Railwaymen tell us about priority, which is provided to military cargo and humanitarian. We understand that - there is a war in the country. But the situation was similar before the full-scale invasion... We would like to, if the products are not delivered in wagons, then at least cross the border by rail. But even here they cannot give us any terms. For example, we see a build-up at a railroad crossing, relatively speaking, 4 thousands of wagons. Capacity of the border crossing per day, suppose, there are a thousand wagons. But UZ cannot guarantee, what for, conditionally, 3-4 days our wagons will cross the border. Rather, will form grain trains. Or with the same rolled metal. Unfortunately, the railway is still an unacceptable option for us. Or a very difficult option.

Confectionery goods are generally transported by rail?

For a long time now, we have only been driving abroad. Of course, by logic, it would be more convenient and cheaper to drive on the track, than in motor vehicles with an internal combustion engine, at the same time "breaking" roads. But for years the railway did everything possible for that, to "transplant" us and other food workers to vehicles. It is not cheap, but this is a more acceptable option for us today, than the railway. In order not to be blocked by the Poles. Actually, this is bad for the economy of Ukraine, because the increase in road transport quickly "breaks" the road infrastructure. So, Of course, it would be better to transport products by rail... But now it is not for us. Unfortunately.

The full text of the interview can be found at the link: https://www.railinsider.com.ua/oleksandr-baldynyuk-konczepcziya-roboty-uz-cze-perevezennya-syrovyny-a-ne-gotovoyi-produkcziyi/

Members of the Ukrainian Business Council, which includes 110 business associations of various sectors of the economy, analyzed draft law No. 5420 regarding the criminalization of smuggling and came to a conclusion, that in the proposed to 2 reading the editorial, this project poses significant threats to law-abiding business, since its provisions are formulated in this way, what contain significant corruption risks, and also pose a threat to the activity of primarily legal business and in no way contribute to solving the problem of shadow imports.

First of all, it should be emphasized, that the limit of criminal responsibility under Article 201-3 of the draft law is unreasonably low. In particular, criminal liability is proposed in case of illegal movement of goods across the customs border in the amount of, with a share of more than 1,342 million. Instead, for the qualification of a criminal offense according to the article 212 of the Criminal Code of Ukraine (CCU) «Tax evasion», the limit of criminal liability for tax evasion (which are customs payments) is 4,026 million. 

Since such changes relate specifically to responsibility for economic crimes and public danger consists precisely in non-payment of taxes and other payments, then it is advisable to be guided by those similar to the content of the article 212 KKU criteria for determining the threshold of criminal responsibility. More, the issue of the customs value of goods is often the subject of a dispute between the declarant and the customs authority, and therefore cannot act as a threshold for criminal liability.

Significant risks for honest business are also seen in the proposed version of the Notes to Art. 201 CCU, which refers to smuggling, including the submission of documents to the customs authority as a basis for the movement of goods, containing false information about the name of the goods, their weight or quantity, country of origin, sender or recipient, the number of cargo spaces, their markings and numbers, false information, necessary to determine the product code according to the Ukrainian classification of goods of foreign economic activity and its customs value, which led or could lead to an unlawful exemption from payment of customs payments or a reduction in their amount. In practice, when declaring goods, the customs authority and the declarant often have disputes regarding the determination of the customs value, product code, country of origin, scales, etc. More, proposed revision of the article 201-3 does not imply necessity proving intent to commit a criminal offense.

At this stage, due to the strike, a significant amount of cargo accumulated on the Polish border. Despite the government's efforts, the problem is not solved quickly, and demonstrates our dependence on the Polish border. After all, even minor strikes lead to a collapse on the western border, and numerous negotiations show that the problem is complex. Russian influence on this situation is not excluded, and the Polish government does not contribute to solving the problem. In general, this problem is systemic and difficulties at the border have been observed before, to this protest action of Polish carriers.

Since the concept of using the "grain corridor" has now changed, including, since the middle of September, this corridor has been operating without the participation of Russia and without the need to agree on the list of goods and ships entering the port - it is worth establishing international container lines to the ports of Great Odesa for the transportation of finished Ukrainian products and the unloading of the western border.

153 vessel, that are transported over 5,6 million metric tons of grain and other cargo - passed through the Black Sea Humanitarian Corridor of Ukraine from September to 24 November 2023 .

If we establish international container lines on this route of the "grain corridor" and expand the list of products, transported through this corridor by other goods with high added value - this will allow to solve several important issues at once.

This will positively affect the cost of logistics, will improve the position of Ukrainian food and other goods on foreign markets, will contribute to an increase in the total volume of exports, as well as this would more than halve the load on car checkpoints and reduce queues at the western borders, including, with Poland and the ports of Gdansk, Renee, Constantius.

For example, before the start of a full-scale war, only confectionery and starch-molasses products provided a sufficiently powerful cargo flow (close 160 th. etc.) through the Odesa port, using sea container transportation. The situation is similar in other food industries.

The full text of the appeal of the Ukrainian Business Council can be found at the link:https://urb.org.ua/shhodo-zavedennya-mizhnarodnih-kontejnernih-linij-v-porti-velikoї-odesi-dlya-rozvantazhennya-zahidnogo-kordonu/