Which Transport Costs Are Included in the Customs Value of Goods?
For imports into Ukraine, customs value includes the cost of transporting goods to the port, airport or other place of entry into Ukraine’s customs territory, together with the associated loading, unloading and handling costs. Amounts already included in the price of the goods must not be added again. Transport costs incurred after entry can be excluded if they are properly distinguished, supported by documents and quantifiable.
The calculation becomes less straightforward when a forwarder issues a single door-to-door invoice, a container arrives through a European port, or the supplier sells goods with delivery to the buyer’s warehouse. Establishing the transport component of customs value requires checking the route, delivery terms and what each payment actually covers.
Customs value, the commercial invoice and the delivery budget
This article addresses the primary valuation method: the transaction value of imported goods under Article 58 of the Customs Code of Ukraine. The starting point is the price actually paid or payable, subject to the adjustments required by law. A commercial invoice helps establish that price, but it does not necessarily show every component needed for customs valuation.
For example, a buyer may pay separately for transport from the factory to the Ukrainian border. That cost is absent from the supplier’s invoice but must still be considered when establishing customs value. Conversely, transport from the place of entry to the buyer’s warehouse may form part of the import budget while being excluded from customs value when properly documented and separated.
Understanding the cost components of international shipping helps establish the full logistics budget. Customs valuation then requires identifying which of those costs meet the criteria set out in the Customs Code.
Which freight and handling costs should be included?
Points 5–7 of Article 58(10) cover transport to the place of entry, loading, unloading and handling associated with that transport, and insurance of the goods. Add these costs only to the extent that they are not already included in the price.
Cost item | Customs valuation treatment |
|---|---|
Road, sea, rail or air transport to the place of entry into Ukraine | Include it if the relevant amount is not already part of the price of the goods. |
Loading, unloading and handling associated with transport to the place of entry | Include the applicable, documented operations without adding amounts already accounted for. |
Fuel surcharges, road tolls and other freight tariff components | Account for them within the cost of the relevant route segment. Do not add them separately if already included in the tariff. |
Cargo insurance | Check the policy and the insurance cost. Article 58 addresses insurance as a separate cost component. |
Transport after entry into Ukraine | Exclude it when the amount is properly distinguished, documented and quantifiable. |
Storage, waiting time, demurrage, detention or a bundled “terminal service” | Do not classify the charge by its name alone. Examine the service, contract, location and connection with transport. |
The carrier’s country of registration does not determine the valuation treatment. A Ukrainian company may perform transport abroad, while a foreign company may invoice the entire journey to a Ukrainian warehouse. The relevant factors are the service, route segment and documented amount.
Where does the transport cost boundary lie?
The reference point is the place of entry into Ukraine’s customs territory. It should not automatically be equated with the consignee’s warehouse or an inland customs terminal where clearance is completed.
If a container arrives in Gdańsk and continues to Ukraine by road, the Polish port is not the place of entry into Ukraine. The transport calculation must therefore address the sea leg, applicable cargo handling in the port and onward transport to the Ukrainian border, to the extent that these costs are absent from the price of the goods.
The same principle applies to air cargo arriving at an EU airport and continuing to Ukraine by truck. An international air waybill does not turn the road journey from that airport to the Ukrainian border into post-entry transport.
When arranging sea container shipping, request a breakdown covering the sea leg, port operations, onward transport to the place of entry and delivery within Ukraine.
How Incoterms affect the customs value calculation
Delivery terms allocate obligations and costs between the seller and the buyer. However, the labels EXW, CIF and DAP do not replace an examination of the price and supporting documents.
Under EXW, check the costs the buyer incurs after collecting the goods at the agreed location, including transport and cargo handling up to the place of entry. Under FOB, the buyer often pays sea freight separately. Under CIF to an agreed port, freight and insurance to that port are generally already included in the supply price and should not be added twice. The article on FOB and CIF explains the allocation of responsibilities in more detail.
Under DAP to a warehouse in Ukraine, the price may include transport both before and after entry. The Ukrainian transport segment can be excluded only when its amount is properly distinguished and supported. DDP also calls for checking any Ukrainian taxes included in the price: these are a separate valuation issue, rather than a freight service. See the explanation of DAP, DDP and DPU for the parties’ respective obligations.
Worked examples: EXW, CIF and DAP
All amounts below are illustrative and expressed in euros for ease of comparison. Assume that the transaction value method applies, all costs are documented and no other mandatory adjustments arise. These examples explain the structure of customs value; they are neither freight quotations nor calculations of import duties and taxes.
Example 1. EXW: the buyer pays for transport
The commercial invoice shows goods worth €20,000. Loading at origin costs €100, transport to the place of entry into Ukraine costs €1,400, and insurance for this shipment up to that place costs €100. None of these charges is included in the goods price. Delivery from the place of entry to the warehouse costs a further €400 and is separately identified in the documents.
Customs value: €20,000 + €100 + €1,400 + €100 = €21,600.
The €400 post-entry leg is not added. It remains a business delivery expense but, under the stated conditions, does not increase customs value.
Example 2. CIF Gdańsk: the goods arrive through an EU port
The invoice price is €30,000, already including sea freight and insurance to Gdańsk. The buyer separately pays €350 for handling associated with onward transport to Ukraine and €1,150 for transport from the port to the place of entry. Neither charge is included in the commercial invoice or the freight already paid. Post-entry transport costs €500 and is documented separately.
Customs value: €30,000 + €350 + €1,150 = €31,500.
Sea freight and insurance to Gdańsk are not added again, and the documented €500 Ukrainian transport leg is excluded. Any additional insurance for the onward journey would require a separate assessment; this example assumes that no such charge arises.
Example 3. DAP Kyiv: delivery is already in the invoice
The supplier issues a €25,000 invoice including delivery to Kyiv. The seller’s documents and transport cost breakdown establish that this price includes €600 for transport from the place of entry into Ukraine to the consignee’s warehouse. This component is properly distinguished from the price.
Customs value: €25,000 − €600 = €24,400.
Without an identified, documented amount, the importer cannot simply deduct an estimated €600. Nor can the entire international freight charge be deducted: the portion relating to transport up to the place of entry must remain in the calculation.
Documents that support transport costs
Article 53 of the Customs Code identifies the documents used to substantiate customs value. For transport costs, the evidence needs to connect the goods, route, service provider and amount charged. The working document set depends on the shipment and may include:
- the international sales contract, specification and commercial invoice;
- the carrier or forwarding agreement and the agreed transport order;
- the freight invoice with a route and tariff breakdown;
- a CMR consignment note, bill of lading, air waybill or applicable rail transport document;
- a transport cost calculation or statement explaining the allocation before and after the place of entry;
- insurance documents and evidence of the insurance cost, where insurance was arranged;
- payment records and other supporting documents applicable to the transaction.
A CMR consignment note or bill of lading establishes transport details but may not show the freight price. An invoice labelled simply “logistics services” gives a total, yet may not explain what it covers. The documents should support and clarify one another.
A transport cost statement should not be treated as a universal replacement for the underlying evidence. It needs to agree with the contract, invoices and actual route. Before dispatch, also check the commercial invoice for the parties’ names, currency, delivery terms and named destination.
Splitting a door-to-door freight rate
Request the breakdown in the transport order before agreeing the rate. Specify that customs valuation requires the place of entry, the transport cost up to that point and the cost of the following segment. Cargo handling, insurance and other services should preferably appear as separate items.
If a single total has already been invoiced, ask the carrier or forwarder for a substantiated calculation that clearly references the invoice. Avoid splitting the charge by mileage alone without considering the actual tariff: road tolls, ferry crossings, handling and different segment rates can materially change the allocation.
For consolidated cargo, the calculation must relate to your particular consignment. Weight, volume or another allocation basis should reflect the agreed pricing method and be supported by the forwarder’s records. An arbitrary percentage of the goods price does not substantiate the actual freight cost.
Insurance, waiting time and port extras need separate checks
Cargo insurance is expressly listed among the additional customs value components. The exclusion for transport after entry does not automatically exclude a corresponding share of the insurance premium. If a policy covers the entire journey to the warehouse, review its terms and premium calculation separately with the customs broker. The sum insured, which represents the coverage amount, should not be confused with the cost of insurance.
For storage, waiting time, demurrage and detention, there is no reliable blanket rule that “charges abroad are always included” or “penalties are always excluded”. An invoice label does not establish the legal nature of a payment. Examine the contractual terms, actual service, charging period and its connection with transport of the goods being valued.
A forwarder’s bundled invoice may contain transport, insurance and document processing services. Do not transfer the total into the transport component without reviewing the individual items. Equally, calling a charge a “forwarding fee” does not, by itself, justify excluding an expense associated with delivery to the place of entry.
What to agree before filing the declaration
Check five points before clearance: the exact place of entry, costs already included in the goods price, separate charges up to that place, documented post-entry transport and consistency between the figures and underlying records. If the route changes or new invoices arise, pass the updated information to the broker so its effect on customs value can be assessed.
Save Pro Solutions arranges international delivery and customs clearance in Ukraine. Send your commercial invoice, delivery terms, route and available freight breakdown: the team can help assemble the transport cost information and coordinate the documents needed to clear your cargo.
