The Ukrainian Agribusiness Club (UCAB) opposes Order #19 of August 18, which, according to agrarians, poses a threat to one of the key logistics routes for exporting Ukrainian agricultural products through Ukrainian ports on the Danube.

UCAB believes that the provisions of the order contradict the legislation of Ukraine and may lead to abuse by regulatory authorities. In particular, the association points to changes in the requirements for the provision of registered tax invoices.

It is emphasized that the order requires registration of tax invoices at the time of submission of the customs declaration, although according to the Tax Code, this should be done almost a month before submission. Farmers also point to technical limitations that complicate the process of registering the weight of goods at the time of declaration.

Farmers also object to the mandatory statistical reporting to the Main Department of Statistics in Odesa region, calling this requirement illegal and impossible to implement. They recall that other regions and exporters report in accordance with Law No. 2115-IX of March 3, 2022, which suspended the deadlines for statistical reporting during martial law.

Order #19 has already resulted in a 20% decrease in agricultural exports, especially through the Danube ports, and this is leaving a negative impact on the country's economy. Therefore, UCAB calls for the abolition of this order, which contradicts the legislation of Ukraine and may lead to a halt in grain exports through sea and Danube ports.

The Association also expresses its readiness to cooperate with the authorities and invites representatives of the relevant state services and the agrarian business community to agree on legal solutions to combat shadow grain exports.