Selling into Ukraine through distributors

How the market buys

Public procurement in Ukraine is governed by Law No. 922-VIII "On Public Procurement" of 25 December 2015. It applies when goods or services are worth UAH 200,000 or more (works: UAH 1.5 million) for public authorities and bodies serving public needs, and UAH 1 million or more (works: UAH 5 million) for buyers in sectors such as gas, electricity, heat and water (Arts. 2 and 3). Procedures run through the electronic procurement system, Prozorro, and below those values buyers may buy outside it; under the martial-law rules, a purchase made outside Prozorro must be reported there, with the supplier's name, only if it is worth UAH 50,000 or more (point 11 of Resolution No. 1178).

Since 2022 a second layer applies. Cabinet of Ministers Resolution No. 1178 of 12 October 2022 sets "Peculiarities" for public procurement during martial law and for 90 days after it ends. Among other routes, buyers use open tenders run under those rules and requests for proposals in the electronic catalogue. The Peculiarities are amended often: the latest change, Resolution No. 1181 of 28 September 2026, took effect on 29 September 2026. A new Law No. 4888-IX "On Public Procurement" of 27 May 2026 replaces Law No. 922-VIII on 24 March 2027; check which rules apply to a procedure before you rely on it.

The law treats foreign suppliers equally: residents and non-residents take part on equal terms, and buyers may not set discriminatory requirements (Art. 5). Documents a buyer prepares are in Ukrainian; it may add an authentic translation, but the Ukrainian text prevails (Art. 12). The Law's rule that larger notices are also published in English (Art. 10(3)) does not apply to open tenders run under the martial-law rules (point 25 of Resolution No. 1178), so expect Ukrainian.

One rule matters for heavy equipment. Under point 6-1 of the Final Provisions, as amended in May 2026, listed goods — among them generator sets, transformers, buses, lorries, rail vehicles, pumps, compressors and construction machinery — worth UAH 1 million or more in a purchase may be bought only if they appear on a list of goods with a confirmed degree of local production (30% in 2026). Goods originating in a party to the WTO Government Procurement Agreement — the EU and its member states count as one party, and Ukraine itself has been a party since 18 May 2016 — or in a country with which Ukraine has a treaty containing procurement provisions, are exempt if a document proves their origin.

Lawful first contact

Two laws apply to e-mail. Article 10 of Law No. 675-VIII "On Electronic Commerce" says commercial electronic messages are sent on the basis of the addressee's consent, but may be sent without consent provided the person can refuse further messages. Each message must be clearly identifiable as commercial and give direct, simple access to the sender's identification details listed in Article 7. The law defines a commercial electronic message as one promoting goods, works, services or a business's reputation, so an e-mail presenting your range qualifies.

Article 120 of Law No. 1089-IX "On Electronic Communications" separately bans the intentional mass sending of messages to users' e-mail addresses without their consent, and the law defines users to include legal persons. Its definition of spam is messages sent without prior consent repeatedly — more than five to one subscriber.

Taken together: a single, individually written, clearly labelled enquiry to one distributor, with your full company details and a simple way to opt out, fits the E-Commerce Law; a mailing to a list of companies without consent does not. Do not keep writing to someone who has not answered: the spam definition counts repeated unsolicited messages to one subscriber. Open in Ukrainian if you can. Other routes work too: a meeting at the sector's trade fair, or an introduction through a partner, an association or an existing customer.

What local distributors expect

• Ukrainian product information. Under Article 30 of the State Language Law, information about goods in Ukraine is provided in Ukrainian; it may be duplicated in other languages.
• A route to Ukrainian conformity. Products covered by a Ukrainian technical regulation must carry Ukraine's mark of conformity with technical regulations where that regulation requires it (Art. 29 of Law No. 124-VIII). Foreign conformity results are accepted under treaties on mutual recognition, and a Ukrainian designated body may rely on test reports from accredited foreign bodies (Art. 45). As of October 2026 we could not confirm that an EU–Ukraine Agreement on Conformity Assessment and Acceptance (ACAA) is in force; the European Commission refers to starting negotiations on one.
• Proof of EU origin for every delivery of goods on the localisation list.
• Prices that work both in open tenders and in the electronic catalogue, which is kept in Ukrainian and settled in hryvnia.
• Delivery terms and lead times the distributor can rely on, spare parts within reach, and references.

How to enter, step by step

1. Check the conformity route. Find out whether a Ukrainian technical regulation covers your product and which designated body can assess it, and ask whether it will rely on your EU test reports (Art. 45 of Law No. 124-VIII).
2. Check the localisation list. If your product is listed in point 6-1 of the Final Provisions of Law No. 922-VIII, plan a certificate or declaration of EU origin for each delivery.
3. Prepare Ukrainian documentation. Product information, technical sheets and a price list in Ukrainian; tender documents are in Ukrainian and that text prevails.
4. Search Prozorro for awards in your CPV codes. ДК 021:2015 is CPV 2008, so search Prozorro or bi.prozorro.org with the codes you already use and note which suppliers win, and for which buyers.
5. Understand the electronic catalogue. Suppliers join after qualification by the catalogue's administrator, a central purchasing body, through the e-procurement system (Resolution No. 822).
6. Shortlist the distributors that win. Suppliers named repeatedly in awards in your category already hold the buyers' trust.
7. Make lawful first contact. One individual, clearly labelled enquiry per distributor, with full sender details and an opt-out; no list mailings without consent.
8. Prepare the first meeting. Bring the conformity route, the proof-of-origin plan, Ukrainian documentation, delivery terms, and pricing for tenders and the catalogue; follow up by e-mail once the distributor has replied.

Where the evidence comes from

Ukrainian awards are published in Prozorro. Under Article 10 of Law No. 922-VIII, the buyer publishes the notice of intention to conclude a contract within one day of choosing the winner, and the contract with its annexes within three working days of signing it. The analytics module bi.prozorro.org shows procurements run through Prozorro, apart from some processes temporarily withheld for national-security reasons, and the public API documented by Prozorro exposes the same records, including awards and suppliers, with items classified under ДК 021:2015.

TED carries only occasional notices involving buyers in Ukraine — a few dozen award notices a year — so it is not a record of Ukrainian awards. Cresques offers markets only in EU and EEA countries today; Ukraine is not among the countries you can choose, and Cresques does not read Prozorro. Search Prozorro or bi.prozorro.org directly, filtering by CPV code and by completed procurements. The awards are evidence of who the buyers already trust; the lawful first contact above is how you reach them.