eExcise in Ukraine: how the electronic excise mark works

From 1 November 2026, alcohol, tobacco products, and e-cigarette liquids in Ukraine must carry electronic excise marks. The paper stamp that served as the control instrument for decades is being retired in favor of a DataMatrix code on every bottle and pack, backed by a state traceability system known as eExcise (еАкциз).

For producers, importers, distributors, and retail this is not a cosmetic change — it is new IT infrastructure on the line, in the warehouse, and at the checkout. We integrate factories with eExcise in production, so this article explains the system the way we would to a fellow engineer or a plant director: what it is, who it affects, the deadlines, and what happens to each unit of product.

What eExcise is

eExcise is Ukraine’s state Electronic System for the traceability of excisable goods. Electronic excise marks were introduced by Law of Ukraine № 3173-IX of 29 June 2023, while the system’s operation and marking rules are defined by Law № 3817-IX. It replaces paper excise stamps with electronic marks and records the movement of every marked unit — from production or import to the final sale.

The state expects four things from it:

Key terms

TermMeaning
Electronic mark (e-mark)The digital successor of the paper excise stamp: a record in the state system plus a graphic element applied to the packaging.
Unique identifier (UI)A code the state generates for each individual unit — one bottle, pack, or liquid container.
DataMatrixThe 2D code that carries the identifier, printed together with the first twelve characters of the UI in human-readable form.
Traceability systemThe state electronic system (administered by the tax service) where every operation with marked goods is reported.
UGIUnique group identifier — the code of group packaging, one level for the box, another for the pallet.
AEDExcise electronic document accompanying any movement of goods — including transfers between an operator’s own warehouses.
QESQualified electronic signature used to sign documents and operations in the system.

Deadlines: what becomes mandatory, and when

Mandatory electronic marking was originally scheduled for 1 January 2026; Law № 4698-IX of 3 December 2025 and Cabinet of Ministers Resolution № 1752 moved the start to 1 November 2026. The current timeline:

PeriodWhat happens
from 1 March 2025Test mode of the system; producers and importers could join voluntarily.
1 January — 11 October 2026The system runs in test mode for all willing operators.
12 — 31 October 2026Operators register and obtain identifiers for working in the system.
from 1 November 2026Marking is electronic only. Paper stamps can no longer be ordered.
until 1 May 2028Remaining stock with paper stamps may still legally be sold through.

Penalties phase in as well: 10% of the standard sanctions from 1 November 2026 to 30 April 2027, 30% from May through October 2027, and the full amount from 1 November 2027. The soft penalties do not move the core deadline, though — goods produced after 1 November 2026 cannot be sold without an e-mark at all.

How it works: one bottle’s journey

  1. Ordering marks. The producer or importer orders unique identifiers in the system and pays the excise tax — the same economic step as buying paper stamps used to be.
  2. Application. On the bottling or packaging line, each unit receives the e-mark’s graphic element: a DataMatrix code plus twelve human-readable characters.
  3. Verification on the line. Every applied code must be read back and matched against the ordered identifiers. An unreadable or duplicated code is a unit that must not enter circulation.
  4. Entry into circulation. The producer reports the activated identifiers; from that moment the state knows the bottle exists, who made it, and when.
  5. Movement through the chain. Shipping to a distributor, warehouse receiving, transfers, delivery to retail — each operation is reported by the parties and signed with a qualified electronic signature.
  6. Sale at the checkout. The cashier scans the DataMatrix; the fiscal receipt carries the identifier and the system retires the mark. Selling the same bottle twice fails — the code is already spent.
  7. Consumer check. Anyone can scan the code in the Diia app and see whether the product is legal.

Who is affected, and what they must build

Producers

The largest share of the change: ordering identifiers, applying and verifying codes at line speed, accounting for rejects, reporting entry into circulation. It is equally an equipment problem (printers, applicators, cameras) and a software problem — connecting the line to the traceability system.

Importers

Marking imported goods and reporting the import. The key operational question is where the code is applied — at the foreign production site or at a customs warehouse.

Wholesale and warehouses

Every receiving, storage, and dispatch operation with marked goods must be reflected in the system. This lands on the WMS: it has to know every identifier on stock and produce movement reports.

Retail

Scanning the DataMatrix at the checkout and passing the identifier in the fiscal receipt. POS software and scanners must handle the new mark.

FAQ

What happens to paper stamps?

They can be ordered and applied until 1 November 2026, and stock marked with them can be sold through until 1 May 2028. After that, only the electronic mark remains.

Is this the same as the EU’s track and trace?

The idea is similar to the EU’s tobacco track & trace (TPD) and other national digital-marking schemes, but eExcise is a separate Ukrainian system with its own formats, reporting rules, and rollout schedule.

Can we comply manually, without integration?

In theory, for minimal volumes — yes, through the system’s cabinet. In practice, for a production line or a warehouse with real throughput — no: at thousands of units per hour, anything short of automated reading, accounting, and reporting turns the system into a bottleneck that stops shipments.

The bottom line

eExcise is not “one more report”. It changes how an excisable product legally exists: without a correctly applied, read, and registered e-mark, the product effectively does not exist. Preparing for that is an engineering project above all — and the cheapest time to run it is now, while the system is still in test mode.

Talk to the engineers who run eExcise in production.

ExciseTrace and ExciseTrace WMS report to eExcise from live factory lines and warehouses every day. If 1 November 2026 is on your calendar, write to us.

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