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Results of the fifth wave of the Annual survey of Ukrainian exporters and importers

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The presentation contains key results of a survey of more than 1,000 Ukrainian companies-exporters and importers, conducted in 2020.

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Results of the fifth wave of the Annual survey of Ukrainian exporters and importers

  1. 1. Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses according to the results of the fifth wave of the annual survey Ukrainian exporters and importers Kyiv 2020 Project "Support to Public Initiative "For fair and transparent customs"
  2. 2. ABOUT THE PROJECT The overall goal of the project is to increase the capacity of civil society to participate in economic policy development in Ukraine. Expected results: (1) strengthening the capacity and effectiveness of the initiative; (2) intensification of political dialogue between civil society and the state on the implementation of customs reform Project implementation period : 36 months, from January 1, 2020. With the financial support of the European Union, the International Renaissance Foundation and the ATLAS Network (USA). Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 2 The initiative is an informal network of CSOs from different regions of Ukraine that care about improving the business climate. 26 members as of September 2020 The activities of the initiative are aimed at monitoring the implementation of customs reform and promoting dialogue on the implementation of institutional reform of customs in accordance with the principles of good governance and the principles of free trade. The public initiative was created in 2018 in the process of implementing the project "Trade Facilitation Dialogue", which was implemented by the IER with the support of the EU and The International Renaissance Foundation
  3. 3. Annual survey of Ukrainian exporters and importers: the basis of advocacy and analytical work of the Initiative The IER has developed and has been implementing since 2015 a special national policy monitoring and evaluation tool, Trade Facilitation Monitoring. It is a tool for measuring progress in facilitating and simplifying international trade and customs procedures, which is based on the assessments of the direct participants in the policy implementation process - business representatives. The monitoring is based on the results of the annual survey of 1000 exporting / importing enterprises throughout Ukraine. There were 5 annual surveys: 2015, 2016, 2017, 2018, 2020 Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 3
  4. 4. 5th Annual Survey: Topics How the business assesses the activities of customs authorities and the implementation of reforms in the customs sector What are the quantitative and qualitative estimates of the cost and duration of foreign trade procedures How the business assesses various procedures (preliminary customs clearance, decision- making on the customs value of goods, classification of goods; post-customs audit, etc.) How the "single window" and electronic document management work Why are cargoes delayed during customs control? Is it easy for companies to appeal the actions of customs authorities? What's with the corruption at customs What do businesses think about "smuggling" and "gray imports" What are the obstacles for importers and exporters How the Association Agreement affected business activities What is the role of business associations Where companies get information Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 4
  5. 5. WHO WAS INTERVIEWED: SAMPLE 5
  6. 6. Sample: what are the types of the surveyed enterprises 6 • 1000+ surveyed representatives of enterprises engaged in export and / or import • Businesses of all sizes were surveyed: from micro-enterprises to large enterprises. Most are micro and small enterprises • Most of the respondents are representatives of industry and trade Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 24,4% 40,8% 34,8% 0% 25% 50% Only exporting enterprises Only importing enterprises Exporting and importing enterprises Enterprises by foreign trade, % 42,3% 28,0% 21,4% 8,2% 0% 25% 50% Micro Small Medium Large Enterprises by size, % 6,6% 46,3% 42,5% 4,6% 0% 25% 50% Agriculture Industry Trade Services Enerprises by sector, %
  7. 7. CUSTOMS PERCEPTION INDEX 7
  8. 8. Customs performance perception index (CPP) 8 • The assessment of the work of customs has improved: the value of the CPP Index reached 0.43 on the scale from -1 to 1 • The CPP Index has been rising over the last three waves of the survey. 0,21 0,10 0,21 0,33 0,43 -1,00 -0,50 0,00 0,50 1,00 2015 2016 2017 2018 2020 Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses
  9. 9. Assessment of customs work: what is behind the CPP Index Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 9 • Almost a third of the respondents consider the customs effective and in no need of change. This is the highest frequency of such responses in all five waves of this survey • More than half of the respondents indicated that the work of customs is generally effective, but requires some changes • The share of the respondents who said the work of the customs is completely or generally inefficient is the lowest in all the five waves of the survey 3,9% 15,3% 52,9% 27,9% 0% 20% 40% 60% Completely ineffective and needs a complete replacement Generally ineffective, but large- scale reforms can improve the situation Generaly effective, but requires some changes Effective and does not need changes
  10. 10. CPP Index: comparison by customs offices 10 • The values of the CPP Index for all customs offices are positive • Poliska Customs Office received the best score: the value of the CPP Index for it was 0.61. • The lowest value of the CPP Index is for Volyn, Kyiv and Dniprovska Customs Offices, but even there positive assessments prevail. * Azov and Skhidna Customs Offices are not included in this analysis due to the insufficient number of the respondents Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 0,33 0,38 0,38 0,40 0,42 0,45 0,50 0,57 0,58 0,58 0,59 0,61 -1,00 -0,50 0,00 0,50 1,00 Volyn Kyiv Dniprovska Slobozhanska Halytska Odesa Zakarpattia Bukovynska Chornomorska Pivnichna Podilska Poliska
  11. 11. CPP Index: comparison by types of enterprises • Exporters assess the work of customs best. Importers assess customs worse than others and more often require large-scale reforms • The best estimates by industry are in the agricultural sector • Medium and large enterprises assess the work of customs much better than small and micro enterprises 11Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 0,63 0,47 0,36 0,38 -1,00 -0,50 0,00 0,50 1,00 Agriculture Industry Trade Services CPP Index by sector 0,38 0,38 0,55 0,51 -1,00 -0,50 0,00 0,50 1,00 Micro Small Medium Large CPP Index by size 0,62 0,32 0,42 -1,00 -0,50 0,00 0,50 1,00 Only exporting enterprises Only importing enterprises Exporting and importing enterprises CPP Index by foreign trade
  12. 12. Problems in the work of customs according to business estimates 12
  13. 13. Problems in the work of customs 13 • The share of the enterprises that did not experience any problems has doubled since 2016 • About a third of only exporting enterprises did not experience any problems; this is twice as many as among those that are only importing • Among the enterprises of different sizes, micro-enterprises most often report problems at customs • The share of agricultural businesses (34.4%) that did not encounter problems in the work of customs is twice as high as the one in trade (18.1%). Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 12,9% 17,3% 21,2% 23,5% 0% 10% 20% 30% No problems in the work of the customs Share of the enterprises that said there are no problems in the work of the customs, % 2020 2018 2017 2016
  14. 14. Problems in the work of customs (2) 14 • Imperfect customs legislation ranks first for all respondents, regardless of their size, sector and type of foreign economic activity • Agriculture is the only sector where the share of the enterprises that did not face any problems (34.4%) exceeds the share of those that named other problems • Deliberate overestimation of the customs value of goods is the second most urgent problem for micro and small enterprises, while frequent changes in the structure and management of the customs, for medium ones, and outdated technical equipment, for large businesses • Micro and small businesses are more likely to report corruption than large and medium-sized businesses Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 23,5% 9,2% 14,0% 18,8% 19,5% 20,2% 20,3% 25,2% 33,3% 0% 10% 20% 30% 40% No problems in the work of the customs Fiscal function of the customs Unprofessionalism of the inspectors Frequent changes in the structure and management Outdated technical equipment Corruption and bribery Insufficient transparency and openness Deliberate overstatement of the customs value of goods Flawed customs legislation Problems in the work of customs, 2020 , %
  15. 15. Problems in the work of customs (3) Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 15 • The situation with problems such as flawed customs legislation and insufficient transparency and openness at customs improved in 2020 • The share of the enterprises that report these problems decreased compared to previous years • The reduction of the problem of flawed legislation, which was mentioned by more than half of the respondents in 2016, is especially noticeable 56,2% 47,4% 45,6% 33,3% 0% 20% 40% 60% Flawed customs legislation Share of the enterprises that reported flawed customs legislation among the problems with the customs, % 2020 2018 2017 2016 30,1% 25,6% 25,1% 20,3% 0% 20% 40% 60% Insufficient transparency and openness Share of the enterprises that reported insufficient transparency and openness among the problems with the customs, % 2020 2018 2017 2016
  16. 16. Problems in the work of customs (4) • Frequent changes in the structure and management of customs is one of the obstacles reported by the respondents. The importance of this obstacle increased in 2020 compared to previous years • This indicates that in the process of change and reform at customs, care must be taken to ensure that this does not interfere with business operations. • This problem is more relevant for medium and large enterprises than for micro and small ones Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 16 23,7% 18,1% 13,8% 18,8% 0% 10% 20% 30% Frequent changes in the structure and management Share of the enterprises that reported frequent changes in the structure and leadership among the problems with the customs, % 2020 2018 2017 2016
  17. 17. Assessment of passing various types of control • The level of problems of all types of control is low: from 61.1% (customs control) to 86.6% (food safety control) respondents have no problems. • Customs control is more problematic compared to other types of control, but the problems are mostly minor. • Passing different types of control is more problematic for importers than for exporters. Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 17 86,6% 78,9% 78,1% 61,1% 0% 20% 40% 60% 80% 100% 120% Food safety control Veterinary and sanitary Phytosanitary Customs Distribution of estimates for different types of control,% 0 points (No problems) 1 point 2 points 3 points 4 points 5 points (significant problems) 0,1 0,2 0,3 0,5 0,5 0,6 0,5 0,9 0,0 0,2 0,4 0,6 0,8 1,0 Food safety control Veterinary and sanitary Phytosanitary Customs Average scores of the difficulty of passing Only importers Only exporters
  18. 18. PERCEPTION OF THE "NEW CUSTOMS" BY BUSINESSES 18
  19. 19. Perception of the work of the "New Customs" 19 Respondents evaluated the work of the New Customs (NС), i. e. the customs that has been operating since December 2019. A comparison was made between the time of the survey (April-June 2020) and the same period in 2019 Almost half of the respondents rated the work of the NC as good and excellent. Only 8% assessed its work as unsatisfactory. Average score is 3.6 out of 5. Only exporters rated the work of the NC higher than other respondents (4 points) • 2/3 of respondents believe that the efficiency of customs has not changed compared to 2019, but positive assessments outweigh negative ones by +13.8 pp • There is almost no difference in the assessment of changes in the work of customs by the type of the enterprises. Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 48,1% 29,7% 8,0% 14,2% 0% 20% 40% 60% Excellent or above average (4 and 5) Average (3) Poor or below average (1 and 2) Hard to say Assessment of the work of the customs in 2020 (1 to 5), % 18,6% 66,2% 4,8% 10,4% 0% 20% 40% 60% 80% Improved Has not changed Got worse It is difficult to estimate How did the work of the New Customs change compared to the same period last year?, %
  20. 20. Assessment of individual aspects of the work of the New Customs 20 • Assessment is are made on the scale from 1 to 5, where 1 is a negative rating and 5 is a positive one. For the "level of corruption“ indicator 1 point means a high level of corruption, 5 points mean a low level or no corruption • Assessment of individual aspects of the work of the New Customs, except technical equipment, is better than the general assessment of its work (3.6) • The technical equipment of the customs was rated slightly lower than other aspects: an average of 3.5 points • 62.3% of respondents rated the level of corruption as low (4 and 5 points). This is more than the share of positive assessments of technical equipment (49.7%), and less compared to other aspects (66% +) Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 3,5 3,8 3,8 3,9 3,9 1,0 2,0 3,0 4,0 5,0 Technical equipment of the customs General impression from communicating with customs officers Competences of customs officers Thoroughness of inspection Level of corruption Average assessment of individual aspects of the work of the New Customs (1 to 5 points)
  21. 21. Assessment of individual characteristics of technical equipment at customs • Assessment of all the studied characteristics of technical equipment of customs are rather high • The ability to submit documents in electronic form is assessed best, which may indicate the success of the implemented measures to automate the work of customs • Software operation speed and the presence of other technical equipment for customs control are assessed the lowest, which indicates the need for further investment in customs infrastructure • Only exporters rated all the characteristics better than others • Large enterprises gave the best marks to such characteristics as the ability to submit documents electronically and the presence of software • In trade, the ability of software to perform its functions is assessed the worst 21Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 3,7 3,7 3,8 3,9 3,9 4,1 4,2 1,0 1,5 2,0 2,5 3,0 3,5 4,0 4,5 5,0 Fast operation of the software Presence of other technical equipment for customs control Ability of other technical equipent to perform its functions Ability of the software to perform its functions Presence of necessary computer hardware Presence of the necessary software Ability to submit documents electronically Assessment of individual characteristics of the technical equipment of the customs
  22. 22. Assessment of individual qualifications of customs inspectors 22 • Respondents rated almost all of the listed qualifications of customs inspectors at 4 or 4+ points out of five • The ability to answer entrepreneurs' questions and provide the necessary information is the lowest: 3.8 out of five. This means there is a need for further training for inspectors • Only exporters are slightly better able to assess the ability of inspectors to answer questions and work with technical equipment for customs control • Medium and large enterprises evaluate all qualifications somewhat better • In trade, the ability of inspectors to answer questions was assessed the lowest, and in the agricultural sector, the highest Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 3,8 4,0 4,1 4,2 4,3 1,0 1,5 2,0 2,5 3,0 3,5 4,0 4,5 5,0 Ability to answer questions from entrepreneurs and provide the information they need Ability to carry out customs clearance professionally and without mistakes Familiarity with legislation Ability to work with other technical equipment for customs control Ability to use software Assessment of individual qualifications of customs inspectors
  23. 23. COST OF CUSTOMS CLEARANCE PROCEDURES 23
  24. 24. Change in the cost of customs clearance procedures compared to 2018: exports 24Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses • The cost of customs clearance of exports continues to grow, but not so fast. For most exporters, monetary expenses did not change, but they have been increasing more often than decreasing. The largest growth was in the agricultural sector, while the least one was in the service sector. • The time of customs clearance of exports continues to decline. The share of the businesses for which customs clearance has become faster exceeds the share of those spent more time on it. The most noticeable decrease is for large enterprises. 0,08 0,13 0,25 0,15 -0,32 -0,35 -0,31 -0,27 -0,4 -0,2 0 0,2 0,4 2016 2017 2018 2020 Dynamics of monetary and time expenses for all customs procedures for exports (balance indicator) Monetrary expenses Time expenses
  25. 25. Change in the cost of customs clearance procedures compared to 2018: imports 25 • The cost of customs clearance of imports continues to increase, but at a slower pace. Importers mostly report that their monetary expenses for customs clearance of imports have not changed over the last 2 years. Only in services the reduction of cost is more common than its growth. • The duration of customs clearance of imports is decreasing, but at a slower pace too. For most importers, it has not changed. For the rest of the importers it mostly reduced. The services sector reports the reduction of the clearance time with the least frequency. Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 0,03 0,15 0,20 0,12 -0,29 -0,30 -0,30 -0,21 -0,4 -0,2 0 0,2 0,4 2016 2017 2018 2020 Dynamics of monetary and time expenses for all customs procedures for imports (balance indicator) Monetrary expenses Time expenses
  26. 26. Speed of customs clearance Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 26 Speed of customs clearance: (1) duration in hours and (2) assessment of respondents. • Duration of customs clearance: 10.4 hours. • Respondents' score: 3.6 points out of 5 possible. The difference between the scores of different types of enterprises is insignificant. High marks "4" or "5" points were indicated by 50.4% of respondents, and low marks "1" or "2" points - only 8.8%. 7,7 14,1 0,0 5,0 10,0 15,0 Exclusively exporters Exclusively importers The average duration of customs clearance, by foreign trade Average duration of examination (h) Average duration for all respondents (h) 12,6 11,1 7,4 4,5 0,0 5,0 10,0 15,0 Micro Small Medium Large Average duration of customs clearance, by size of enterprises (h) Average durationfor all respondents (h) 11,6 7,9 12,7 12,8 0,0 20,0 Agriculture Industry Trade Services Average duration of customs clearance, by sector (h) Average duration of examination (h) Average duration for all respondents (h)
  27. 27. Speed of customs clearance (by customs) Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 27 Note: Due to insufficient filling of the subsample, Azov and Shidna Customs Offices are not included in this analysis. It is also not possible to analyze by groups (sector, size) for individual customs. Duration of customs clearance: • Fastest: Zakarpattia (4.3 hours) and Pivnichna (4.8 hours) Customs Offices. • Longest: Odesa Customs Office (16.7 hours). Evaluation of respondents : • The highest scores - at the Pivnichna Customs (3.9 points), where the duration of registration is one of the lowest. • The lowest score is for Odesa Customs Office (3.4 points), where the longest clearance. • For most customs, the scores are almost the same as the average for all respondents (3.6 points) 16,7 13,3 13,1 11,9 11,7 11 8,5 8,2 6,6 6,4 4,8 4,3 0 2 4 6 8 10 12 14 16 18 Odesa Volyn Dniprovska Chornomorska Slobozhanska Kyiv Podilska Halytska Bukovynska Poliska Pivnichna Zakarpattia Average duration of customs inspection, by customs (hours)
  28. 28. Speed of customs inspection Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 28 Speed of customs inspection: (1) duration in hours and (2) assessment of respondents. • Duration of customs inspection: 2.5 hours. • Respondents' score: 3.8 points out of 5 possible. The difference between the scores of different types of enterprises is insignificant. High scores of "4" or "5" points were given by 51.5% of respondents, and low scores of "1" or "2" points - only 5.1 %. 2,2 3,3 0,0 1,0 2,0 3,0 4,0 Exclusively exporters Exclusively importers Average duration of customs inspection, by foreign trade Average durationof examination (h) Average durationfor all respondents (h) 2,8 3,1 2,1 1,5 0,0 1,0 2,0 3,0 4,0 Micro Small Medium Large Average duration of customs inspection, by size of enterprises (h) Average durationof examination (h) Average durationfor all respondents (h) 11,6 7,9 12,7 12,8 0,0 20,0 Agriculture Industry Trade Services Average duration of customs clearance, by sector (h) Average duration of examination (h) Average duration for all respondents (h)
  29. 29. Speed of customs inspection (by customs offices) Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 29 Duration of customs inspection: • Fastest: Zakarpattia (1.1 hours) and Pivnichna (1.4 hours) Customs Offices. • The longest inspection: Odesa Customs Office (4.3 hours). Evaluation of respondents: • The highest score is at the Pivnichna Customs Office (4.3 points), where the duration of the inspection is one of the lowest. • One of the lowest scores is for Odesa Customs Office (3.7 points), where the longest inspection. • For most customs, the scores are almost the same as the average for all respondents (3.8 points). Note: Due to insufficient filling of the subsample, Azov and Skhidna customs are not included in this analysis. It is also not possible to analyze by groups (sector, size) for individual customs. 0 0,5 1 1,5 2 2,5 3 3,5 4 4,5 5 Odesa Slobozhanska Dniprovska Podilska Kyiv Halytska Chornomorska Bukovynska Volyn Poliska Pivnichna Zakarpattia Average duration of customs inspection, by customs offices (hours)
  30. 30. EXPENSES FOR CUSTOMS PROCEDURES 30
  31. 31. Expenses for customs procedures in export operations The total cost of 1 export transaction can average 4186 UAH. • The average time cost for 1 export operation is 8.9 hours, which is almost 2 times less than for imports. • Official and unofficial payments, penalties for exports are on average 2-3 times lower than for imports. • Penalties can be the largest component of the financial cost of exports. • The average fine during export operations exceeds the average size of unofficial payments by almost 30 times. • Low informal payments in the context of high fines may indicate a low probability of punishment. Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 31 721 2879 49022 1784 0 10000 20000 30000 40000 50000 60000 Labor costs Official payments Penalties Informal payments Average costs per export transaction (by type of costs), UAH Average total costs
  32. 32. Costs of customs procedures for import operations The total cost of 1 import transaction can average UAH 8429. The average time cost for passing 1 import operation is 16 hours, which is almost 2 times more than for exports. • Official and unofficial payments, penalties for imports are on average 2-3 times higher than for exports. • Penalties can be the largest component of the financial cost of imports. • The average fine during import operations exceeds the average amount of informal payments by almost 16 times. • Low informal payments in the context of high fines may indicate a low probability of punishment. Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 32 1296 5820 102687 6453 0 20000 40000 60000 80000 100000 120000 Labor costs Official payments Penalties Informal payments Average costs per import transaction (by type of costs), UAH Average total costs
  33. 33. Expenses for customs procedures in export and import operations Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 33 • On average, the cost of one export operation is 2 times lower than for one import operation. • The higher costs of import operations than export operations may be reflected in other aspects of customs procedures (e.g. passing various types of controls), for which importers' assessments are worse than those of exporters. Note: The filling of the subsamples is insufficient for the analysis of average costs in terms of size of enterprises and sectors. 721 1296 3465 71334186 8429 0 2000 4000 6000 8000 10000 Export Import Total average costs for an export of import operation, UAH Labor costs Average financial costs
  34. 34. CUSTOMS REFORMS: ASSESSMENT AND EXPECTED RESULTS 34Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses
  35. 35. Is the customs reform moving in the right direction? Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 35 • The share of enterprises that consider the direction of reforms at customs to be right exceeds the share of those that consider it wrong. • About half of the respondents do not know about the reform or could not evaluate it ("Hard to say" + "I do not know" / refusal to answer) • Large enterprises more often than others call the direction of reforms right • Importing companies, more often than not exclusively exporters, consider the direction of reforms to be wrong. 15,8% 10,3% 36,9% 36,9% 0% 10% 20% 30% 40% 50% Do not know about the reform/Refused to answer In the wrong or mostly wrong direction Hard to say In the right or mostly right direction
  36. 36. Expectations of businesses from the customs reforms • The main expectations of business respondents from the customs reform are to reduce the time of customs procedures, the automation of customs procedures with minimization of the human factor, as well as the ability to submit documents completely electronically. • The lowest priority has been given to the increase in customs revenues to the state budget. Trade Facilitation in Ukraine: Customs Reform Through the Eyes of Businesses 36 34,4% 37,8% 46,9% 47,7% 51,8% 54,5% 61,1% 61,4% 62,6% 65,6% 66,0% 67,9% 0% 20% 40% 60% 80% Increase in customs revenues to the state budget Reduction of the fiscal role of the customs Reduction of the financial cost of customs procedures Reduction of corruption Improvement in the technical equipment of customs Raising professional qualification of customs officers Strengthening security functions Personal responsibility of customs officers for the caused harm Strengthening the fight against smuggling Ability to submit documents only in an electronic form Automation of procedures Reduction of time of customs procedures
  37. 37. THANK YOU FOR YOUR ATTENTION! 37
  38. 38. QUESTIONS? 38
  39. 39. CONTACTS Project "Support to the Public Initiative" For Fair and Transparent Customs " performed by the Institute for Economic Research and Policy Consulting with financial support European Union, the International Renaissance Foundation and Atlas Network web: www.tfd.ier.com.ua e-mail: customs@ier.kyiv.ua Facebook: www.facebook.com/tfd.ier 39

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