IMEI declaration when importing phones: what will change for importers and sellers

The Ministry of Finance has approved the mandatory submission of the IMEI of each mobile phone during customs declaration. Order No. 380 has been registered by the Ministry of Justice but will enter into force only on the date of its official publication. Therefore, state registration of the order does not yet mean that the new requirement must already be followed.

An ordinary store that purchases phones from a Ukrainian supplier will not submit IMEI numbers to customs. The direct obligation applies to the importer or its customs representative. Sellers remain subject to the requirements regarding documents confirming the origin of goods, inventory accounting, ECR/pECR, warranties, and compliance of radio equipment. Mandatory indication of IMEI in the fiscal receipt is not currently required.

What the IMEI declaration order provides for

Order of the Ministry of Finance dated July 13, 2026, No. 380 was registered by the Ministry of Justice on July 30, 2026, under No. 1098/46492. The document changes the rules for completing box 31 of the customs declaration established by Ministry of Finance Order No. 651.

The requirement applies to goods under the following Ukrainian Classification of Goods for Foreign Economic Activity codes:

Box 31 of the customs declaration will have to state: «See “electronic list”». A list of IMEI numbers for each individual item will be attached to the declaration as a separate electronic document. Information about this document must be specified in box 44 of the customs declaration under the relevant code of the Document Classifier.

The amendment was made to Chapter 2 of Section II of Procedure No. 651. Therefore, legally, it applies not only to ordinary imports but also to the declaration of phones under the customs regimes of re-import, temporary admission, inward processing, customs warehousing, free customs zones, duty-free trade, and other regimes covered by this chapter.

The State Customs Service must update its software within one month after the official publication of the order. This period does not replace the effective date: the order expressly states that the new requirement takes effect on the date of its official publication.

Who is directly affected by the new requirement

The business owner imports phones directly

The importer must provide the customs broker with a complete list of IMEI numbers and ensure that it corresponds to the devices actually imported. The broker is not solely responsible for the accuracy of the source data: the declarant and importer must verify the information before submitting the declaration.

It is advisable to include in the contract with the foreign supplier an obligation to provide an electronic list containing at least the following data:

• manufacturer and model;

• item number or model code;

• number of devices;

• IMEI of each unit;

• box, pallet, or batch number, if used;

• separate IMEI numbers for devices with multiple SIM slots or eSIM.

The format of the electronic list and the procedure for indicating IMEI1, IMEI2, and other identifiers must be agreed with the customs broker in accordance with the technical requirements of the State Customs Service. The order does not establish the file structure and does not provide grounds for independently creating a document code for box 44.

Before declaration, it is necessary to check:

• whether there are any duplicate IMEI numbers;

• whether the number of identifiers corresponds to the number of phones;

• whether the IMEI numbers in the file, on the packaging, and on the device itself match;

• whether all IMEI numbers of phones with two or more radio modules are included;

• whether the list contains any devices from another batch.

The store purchases phones from a Ukrainian supplier

The store does not submit a customs declaration if it is not the importer. Order No. 380 does not require such a seller to obtain a copy of the customs declaration for each delivery or to provide IMEI numbers to government authorities.

The seller must have proper primary documents from its supplier: a delivery note, acceptance and transfer certificate, consignment note, or another document that makes it possible to identify the supplier, goods, quantity, and value. For phones, it is advisable to obtain a separate IMEI register attached to the delivery note. This makes it possible to match each device with a specific delivery, supplier, sale, and warranty claim.

The absence of an IMEI in an ordinary delivery note does not in itself make the document invalid. However, the lack of individual item tracking makes it more difficult to confirm the origin of a specific phone during an inspection, return, warranty repair, or claim regarding an IMEI mismatch.

Phones are already in stock

The order does not require phones whose customs clearance was completed before it entered into force to be declared again. There is also no requirement to submit to customs the IMEI numbers of stock that is already in the retail network.

The seller should reconcile the stock by checking:

• the device;

• the IMEI on the packaging;

• the IMEI in the accounting system;

• the supplier’s document;

• the date and goods receipt document.

Used phones

Selling used phones does not create an obligation to submit their IMEI numbers to customs if the seller does not import them. However, the business owner must properly document the purchase of each device and record it in inventory before sale.

The purchase document should specify the model, package contents, condition, IMEI, price, seller details, and confirmation of transfer of the device. When purchasing from an individual, the business owner must also take into account their tax obligations as a tax agent, depending on the nature of the transaction.

Personal import by individuals

Order No. 380 amends the Procedure for completing customs declarations using the Single Administrative Document form. It does not amend the separate Procedure for declarations completed by individuals for goods imported for personal, family, and other non-business purposes.

At the same time, the quantity, nature, and frequency of imports may indicate a commercial purpose. In that case, the rules for business imports apply rather than the exemptions for personal belongings.

Does the IMEI need to be indicated in the fiscal receipt

The current Regulation on the form and content of settlement documents does not include IMEI among the mandatory details of a fiscal receipt. Therefore, the seller is currently not required to transmit the IMEI through an ECR or pECR.

The Economic Security Bureau has reported that indicating IMEI in fiscal receipts is being considered as the next stage, and the relevant mechanism is only being developed together with the Ministry of Finance and the State Tax Service. Until the regulations are amended, this is not an obligation for the seller.

The sale of a phone must be processed through an ECR/pECR under the general procedure when the buyer pays:

• in cash;

• by payment card through a POS terminal;

• through online acquiring;

• upon delivery — if the selected payment scheme involves a settlement transaction.

For a direct transfer from the buyer’s account to the seller’s current account using IBAN details, an ECR/pECR is generally not used because this is a banking transaction without the seller using a payment card. For cash on delivery, the agreement with the carrier or postal operator should specify who accepts the payment, who performs the settlement transaction, and what document the buyer receives.

The product name on the receipt must identify it unambiguously. The entry «phone» is not sufficient to properly distinguish the assortment; it is advisable to specify the manufacturer, model, memory capacity, and another material characteristic.

Inventory accounting of phones and documents confirming their origin

Smartphones and mobile phones are included in the list of technically complex household goods subject to warranty repair. Therefore, Sole Proprietorships that sell them are required to maintain inventory accounting in accordance with Ministry of Finance Order No. 496. This also applies to Sole Proprietorships — single tax payers that are not registered as VAT payers.

Documents confirming the accounting and origin of goods include:

• invoices;

• transport documents;

• customs declarations;

• purchase certificates;

• fiscal and sales receipts;

• other documents that make it possible to identify the supplier, recipient, transaction date, name, quantity, and value of the goods.

The phone must be entered in the Inventory Accounting Form before it is offered for sale. The Form and primary documents must be kept at the place of sale or storage. During an inspection, the electronic form must be provided in a format suitable for viewing and copying.

Procedure No. 496 does not require the IMEI to be specified in the Inventory Accounting Form itself. However, for phones it is advisable to maintain an additional item-by-item register linking the IMEI to:

• the goods receipt document;

• the supplier;

• the warehouse or store;

• internal transfer;

• the fiscal receipt or delivery note;

• the buyer, if their data is collected lawfully;

• the warranty certificate;

• return or write-off.

Marking, declaration of conformity, and warranty

A mobile phone is radio equipment and must comply with the Technical Regulation on Radio Equipment. Before sale, the distributor must check:

• the presence of the conformity mark required by technical regulations;

• the designation of the type, model, batch, or serial number;

• manufacturer and importer details;

• a copy of the declaration of conformity or a simplified declaration containing a reference to the full text;

• instructions and safety information in Ukrainian.

If the seller has reason to believe that the phone is non-compliant or unsafe, it must not be placed on the market until the violations have been remedied. Storage and transportation conditions must not compromise the equipment’s compliance with the established requirements.

Warranty documents for a phone may be provided in paper or electronic form. They must contain information about the product, model, serial number, date of sale, manufacturer, seller, service center, warranty period, and service conditions. The IMEI may be used as an identifier of a specific device, but it must be correctly matched with the manufacturer’s serial number.

The rules for exchange, return, and warranty repair do not change due to the introduction of customs IMEI tracking. A phone of proper quality may be exchanged within 14 days if it has not been used and its appearance, properties, seals, labels, and settlement document have been preserved. For defective goods, the requirements of Article 8 of the Law on Consumer Rights Protection apply.

Licenses, premises, and personnel

Retail or wholesale trade in mobile phones is not a licensed type of business activity. Order No. 380 does not introduce:

• a license for selling phones;

• a permit to maintain an IMEI register;

• special qualifications for sellers;

• separate requirements for the area of a store or warehouse;

• a new permit for storing phones;

• grounds for revoking the seller’s license.

A separate product license for importing ordinary mobile phones is also not provided for in the lists of licensed imports for 2026. The general requirements remain in force regarding state registration of the business, relevant types of activities, customs registration of the importer, retail service, fire safety, occupational safety, and lawful use of the premises.

Violation of technical regulation requirements may result not in the revocation of a «phone license», which does not exist, but in restrictions on or prohibition of the sale of specific products, their withdrawal or recall, and the application of fines under state market surveillance legislation.

Taxes on the import and sale of phones

IMEI declaration is not a new tax or customs payment. The order does not change:

• import duty rates;

• the rules for determining customs value;

• import VAT taxation;

• retail sales taxes;

• the rules of the simplified or general taxation system.

The importer pays customs duties under the general rules depending on the UCGFEA code, customs value, country of origin, and applicable tariff preferences. The order does not establish a separate fee for entering the IMEI in the customs declaration.

Liability for violations

Order No. 380 does not establish a separate fine specifically for the absence of an IMEI. After it enters into force, a declaration without the proper electronic list may fail format and logical control or customs clearance. If false or incomplete information is submitted to customs, liability will be determined under the Customs Code depending on the nature of the violation, its consequences, and the declarant’s fault.

The following main sanctions apply to sellers:

Does IMEI declaration pose a privacy risk

The customs list will contain IMEI numbers and data about the import transaction, but Order No. 380 does not provide for the transfer to customs of the buyer’s full name, SIM card number, phone number, or data about network activity.

An IMEI by itself identifies equipment. It becomes personal data in a context where it can be linked to a specific individual. Such linkage requires a lawful purpose, an appropriate legal basis, limitation of the amount of data, a defined retention period, and proper protection.

Future indication of IMEI in a fiscal receipt could expand device traceability, but the relevant regulatory mechanism does not yet exist. The current order does not create a single system that automatically links customs declarations, buyer data, SIM cards, and mobile network activity.

IMEI, smartphone movement, and warranty accounting in Torgsoft

Torgsoft offers the additional function «Warranty product accounting by serial numbers». A phone’s IMEI can be used as the serial identifier of a specific unit. During goods receipt, the number is entered manually or scanned from a barcode. In strict warranty accounting mode, the program does not allow an identifier that is already in stock to be received again or a phone with a number that is absent from stock to be sold.

The serial number accompanies internal transfers, sales, customer returns, returns to the supplier, write-offs, and inventory counts. In warranty accounting, you can find a phone by its number and view its supplier, goods receipt invoice, purchase date and price, sale date, buyer, and warranty period. During a sale, the program can generate a warranty certificate, and during an inventory count it can identify a stock mismatch where one number is recorded in the system but another is actually in stock.

This function provides internal item-by-item accounting, but the Torgsoft help documentation does not confirm automatic generation of the customs electronic list or its transmission to the State Customs Service. For direct imports, data exchange with the supplier and customs broker must be organized separately. For phones with two IMEI numbers, the method of storing both identifiers must be agreed in advance because standard warranty accounting is designed for one serial number per product unit.

What phone sellers need to do

1. Determine whether the business is an importer or only purchases phones in Ukraine.

2. For direct imports — add a requirement for an electronic IMEI list to contracts with suppliers.

3. Agree with the customs broker on the file format, document code, and procedure for handling phones with multiple IMEI numbers.

4. During goods receipt, compare the IMEI on the box, in the device, in the supplier’s documents, and in the accounting system.

5. Maintain item-by-item tracking of phones from goods receipt through sale, return, or write-off.

6. Keep the primary documents for the goods at the place of sale or provide access to their electronic form.

7. Check the conformity mark, declaration of conformity, Ukrainian-language instructions, and importer details.

8. Do not modify fiscal receipts to include IMEI until separate regulatory requirements enter into force.

9. Do not link IMEI with the buyer’s personal data without a defined purpose and legal basis.

Official sources

• Order of the Ministry of Finance of Ukraine dated 13.07.2026 No. 380 «On amending the Procedure for completing customs declarations using the Single Administrative Document form» — paragraph 1: electronic IMEI list; paragraph 2: software updates; paragraph 4: entry into force.

• Order of the Ministry of Finance of Ukraine dated 30.05.2012 No. 651 — Chapter 2 of Section II, rules for completing boxes 31 and 44 of the customs declaration.

• Customs Code of Ukraine No. 4495-VI — Articles 257, 264, and 335 concerning declarations and documents; Articles 472 and 483 concerning liability for failure to declare and concealment from customs control.

• Law of Ukraine No. 265/95-VR on the use of ECRs — Article 3, in particular paragraphs 1, 2, and 12; Article 17, paragraph 1; Article 20.

• Order of the Ministry of Finance of Ukraine dated 21.01.2016 No. 13 — Regulation on the form and content of settlement documents; current list of mandatory details of a fiscal receipt.

• Order of the Ministry of Finance of Ukraine dated 03.09.2021 No. 496 — Section I, paragraph 2; Section II, paragraphs 1–11 concerning inventory accounting and primary documents.

• Resolution of the Cabinet of Ministers of Ukraine dated 16.03.2017 No. 231 — list of technically complex household goods; group 8517 includes smartphones and mobile phones.

• Resolution of the Cabinet of Ministers of Ukraine dated 24.05.2017 No. 355 — Technical Regulation on Radio Equipment, paragraphs 20–45 and 54–61 concerning identification, marking, declaration of conformity, and the obligations of importers and distributors.

• Resolution of the Cabinet of Ministers of Ukraine dated 28.11.2023 No. 1251 — Procedure for warranty repair, servicing, and warranty replacement of technically complex household goods.

• Law of Ukraine No. 1023-XII «On Consumer Rights Protection» — Articles 8, 9, and 13 concerning defective goods, exchange of goods of proper quality, and distance selling.

• Law of Ukraine No. 2297-VI «On Personal Data Protection» — Articles 6, 8, and 24 concerning the purpose of processing, data subject rights, and personal data protection.

• Economic Security Bureau announcement on IMEI declaration — official information on the purpose of the new requirement and preparation of the future mechanism for indicating IMEI in fiscal receipts.