Uzbekistan publishes draft law overhauling customs administration and introducing new customs liability regime

6 June 2026

A draft law amending Uzbekistan's Customs Code and Code on Administrative Liability was published for public consultation from 18 May to 2 June 2026. Prepared by the Ministry of Economy and Finance, the draft introduces a dedicated legal framework for customs offences and liability, alongside a broad set of procedural changes covering debt collection, customs broker and express carrier obligations, and time limit calculation rules. As a draft, specific figures and provisions may be revised before adoption, but the underlying direction of the reform is unlikely to change. If enacted, the law would take effect three months after official publication, with the new customs liability chapter applying from 1 January 2028.

Why this reform was introduced

The explanatory note accompanying the draft states that growing external trade volumes have been accompanied by a rise in attempts to evade customs payments and circumvent customs rules, including by exploiting incentives and simplified procedures intended to support legitimate business. The draft's stated purpose is to ensure timely and full collection of budget revenue, prevent violations of customs legislation, and establish liability measures based on the principle of proportionality.

A new dedicated customs liability framework

The most consequential element of the draft is an entirely new section of the Customs Code establishing customs offences and liability as a distinct legal category, separate from general administrative liability. This follows the same direction as the draft Law on Financial Penalties published for consultation in May, reflecting a broader move toward structured, sector-specific liability regimes. The core architecture, separating customs liability from general administrative liability and anchoring it in proportionality and burden-of-proof principles, is consistent with that parallel reform and is likely to survive into the final law even if individual provisions are adjusted.

Core principles set out in the draft include:

• Liability applies to legal entities and individual entrepreneurs, established only once a customs authority decision confirming the violation has taken legal effect
• The burden of proving the fact of a violation and the entity's fault rests with the customs authority, not the company
• A person is not considered guilty until guilt is proven in the manner prescribed by law
• Liability is excluded in cases of force majeure, when there is no fault, when the violation resulted from following written guidance previously issued by the customs authority itself, or when the statute of limitations of three years has expired

Specific offences and penalty structure

The draft sets out four specific categories of customs offence with defined penalties. These figures are as currently drafted and may be adjusted during the legislative process, but the structure of fixed-percentage, proportionate penalties is expected to remain:

• Understating customs payments through incorrect tariff classification, undervaluation, or misuse of preferences: a fine of 100% of the additionally assessed customs payments, rising to 200% for repeat violations within one year
• Unlawful disposal, loss or destruction of goods under customs control: a fine of 100% of the payments due on release for free circulation, rising to 200% where the goods should have undergone customs inspection but did not
• Using goods released under conditional exemptions for purposes other than those justifying the exemption: a fine of 100% of the exemption value, rising to 200% for repeat violations
• Failure to submit, or late or inaccurate submission of, advance electronic information on incoming goods, vehicles, passengers and baggage: a fixed fine of 100 times the base calculation unit

Voluntary early payment significantly reduces the penalty under the current draft. Paying 50% of the fine within fifteen days, or 70% within thirty days, releases the company from the remaining amount.

Procedural changes to debt collection and enforcement

The draft restructures how customs authorities collect outstanding customs payments. Collection would follow a defined hierarchy: first from the debtor's bank accounts, then from guarantee providers such as banks or insurers where a guarantee was used, then from customs brokers or express carriers who share joint liability with the declarant, and only then from the debtor's other property in a specified order of priority, generally beginning with cash and ending with assets directly used in production. New provisional measures would allow customs authorities to seize a debtor's property or freeze funds where there are reasonable grounds to believe that collection would otherwise be obstructed.

Customs brokers and express carriers

The draft introduces parallel, detailed liability regimes for customs brokers and express carriers, including joint liability with the declarant for unpaid customs payments in defined circumstances such as incorrect tariff classification or misapplication of preferences, unless the error stems from inaccurate information provided by the client. Both categories would notify customs authorities of their operations rather than obtain prior authorisation, and would need to maintain a registered specialist with customs clearance qualifications, provide payment guarantees, and undergo qualification renewal every two years. A new electronic registry for customs brokers and express carriers would be maintained through the existing licensing information system.

Other procedural changes

The draft also introduces new rules for calculating statutory time limits under customs legislation, extends the maximum customs warehousing period to three years in certain bank- or insurance-guaranteed cases, reduces the temporary import threshold for commercial vehicles before a special fee applies, and would allow border guard units to notify customs authorities directly and temporarily hold individuals suspected of customs violations during border crossing.

Companies engaged in cross-border e-commerce and parcel shipments should note that the draft also updates the rules for international postal and courier shipments, including a new electronic shipment declaration document and simplified declaration thresholds, building on the bonded warehouse and e-commerce framework introduced in April 2026.

What this means for your business

The new customs liability chapter, if enacted broadly as drafted, would give international companies operating in Uzbekistan a far clearer picture of customs enforcement risk than exists today. The shift toward fixed penalty percentages, statutory defences, a burden of proof resting with the customs authority, and a structured early payment discount would be a significant improvement on the current largely discretionary enforcement environment.

At the same time, the new joint liability provisions for customs brokers and express carriers mean that companies relying on third-party customs intermediaries should start reviewing their service agreements and due diligence procedures now, since errors in tariff classification or use of preferences could result in shared financial exposure once the law takes effect. The public consultation closed on 2 June 2026, and the customs liability provisions are not scheduled to take effect until 1 January 2028. While the final text may differ in detail, companies should treat the overall direction as settled and use the time before adoption and entry into force to prepare.