Kiri

Embassy of Ukraine in the Republic of Estonia Lahe 6 Our Ref: 13.04.2023 No 24.1-6/2023/1475- 2 15170, Tallinn Ukrainian vehicles Dear Ambassador, Thank You for your letter No. 6126/22-500-26193 concerning the registration of vehicles belonging to Ukrainian citizens who arrived in Estonia as a result of Russian military aggression. Unfortunately, after careful consideration, the Ministry of Economic Affairs and Communications has come to the conclusion that the current exemption of not requiring the registration of vehicles belonging to Ukrainian citizens cannot be extended on the grounds of road safety. A detailed explanation of our stance in connection with your letter is the following: Subsection 1 of § 76 of the Road Traffic Act states that „A motor vehicle and its trailer must be registered in accordance with the established procedure and bear state registration plates. A motor vehicle or its trailer, which is used in road traffic, must be registered within five working days after putting the vehicle into service in Estonia for the first time“. Subsection 3 of § 76 of the same act further states „A motor vehicle or its trailer used by a person permanently residing in Estonia, natural person who has obtained a residence permit in Estonia and a legal person who is registered in Estonia is subject to registration. Also subject to registration are a motor vehicle and trailer that have been in Estonia for more than one year and are put into service by a natural person permanently residing in a foreign state, a legal person and a self-employed person registered in a foreign state.“ Until now, citizens of Ukraine have been considered to be under the second sentence of § 76, subsection 3, i.e. as if they were persons permanently residing in a foreign state. If a person has been here for more than a year, one can no longer be considered a permanent resident of a foreign state, especially if there is no legal basis for this. Since Ukraine does not set an obligation for technical inspection for vehicles in private use, we also do not have data and assurance that these vehicles are safe to drive. As a concession, we have already changed the national type approval regulation, according to which a Ukrainian vehicle can Suur-Ameerika 1 / 10122 Tallinn / ESTONIA Phone: +372 625 6342 / Fax: +372 631 3660 / E-mail: [email protected] / http://www.mkm.ee be registered here under more lenient conditions, i.e. they are not required to meet the emission requirements if the vehicle does not have EU type approval. Regarding customs concerns, we can note that in the same situation, Estonia or other European Union countries do not require payment of customs duties, as according to EU law, a natural person from a third country who is permanently residing in the customs territory of the European Union can import personal belongings duty-free. An option for Ukraine would be to evaluate the rules concerning customs so that returning citizens do not have to pay customs duties for vehicles that have already been previously registered in Ukraine. However, we are currently analysing and looking into the possibility of whether it would be possible to change the national regulation so that when a Ukrainian vehicle is registered in the Estonian registry, the vehicle's Ukrainian registration documents and license plates are stored and can therefore be returned when the person leaves Estonia and the vehicle is deleted from the Estonian registry. It is our hope that this explains our reasons behind the decision to require the registration of the vehicles in question. With best regards, (signed digitally) Sander Salmu Deputy Secretary General for Transport Margus Tähepõld +372 625 6490 [email protected] /*Copy to Välisministeerium 2 (2)