Виробництво вибухівки

Stage: 1

Idea Formation

Current State

At this stage, stakeholders initiate the concept of creating a new enterprise or launching ammunition production. Ukrainian legislation does not regulate a separate pre-project planning stage for defence industry enterprises, so all preparatory activities (market research, partner engagement, technology selection) occur without regulatory guidance. The absence of state support at this stage undermines the effective formation of industrial clusters and project-based cooperation.

Stage: 2

Company Registration

Current State

Company registration is carried out according to the Civil Code of Ukraine, the Law of Ukraine "On State Registration of Legal Entities, Sole Proprietors and Public Organizations," and the Law "On Limited Liability Companies."

At this stage, the legal form, economic activity codes, location, and ownership structure are defined. However, current legislation does not provide a specific registration regime for enterprises intending to engage in ammunition and explosive material production.

Stage: 3

Obtaining Ammunition Manufacturer Status

Current State

Currently, the status of an ammunition manufacturer is granted temporarily under Resolution of the Cabinet of Ministers of Ukraine No. 763, which is experimental and only valid during martial law. The absence of a permanent regulatory framework creates legal uncertainty for companies and their partners.

Stage: 4

Obtaining Land for Production, Storage, and Testing

Current State

The process of acquiring land for the purposes of ammunition/explosives production, storage, disposal, or testing requires changes to the land's designated purpose according to the Land Code of Ukraine and the Law "On State Registration of Property Rights to Immovable Property and Their Encumbrances."
This change is a separate administrative procedure that includes:

preparation of urban planning documentation,

development of land management technical documentation,

approvals from various authorities (architecture, StateGeoCadastre, local council or administration),

public hearings (in certain cases),

amendments to the State Land Cadastre.

This multi-step and lengthy process creates barriers to the timely launch of defense production, even under martial law or emergency conditions.

Stage: 5

Production and Storage Locations

Current State

Currently, location requirements are defined by various industry-specific regulations, most of which are not adapted to the specifics of ammunition. Security requirements are often not integrated, and permits for storage and production are issued by different authorities.

Stage: 6

Handling Classified Information

Current State

Current legislation (the Law of Ukraine "On State Secrets" and SSU procedures) does not account for the production-specific needs of ammunition enterprises. The procedures are lengthy, and the criteria for obtaining access permits are non-transparent.

Stage: 7

Procurement of Explosives and Initiation Devices

Current State

The procurement of explosives, precursors, initiation devices, and other sensitive components for ammunition production is regulated by various acts issued by the Ministry of Internal Affairs, State Labor Service, State Export Control Service, and tax regulations. Procedures are scattered, and applications and approvals are handled through separate channels. There is no unified procurement process within or outside the framework of the state defense order.

Stage: 8

Logistics

Current State

Transportation of explosives, precursors, and military-purpose products requires permits from the Ministry of Internal Affairs and route approvals. There is no unified document that sets out clear rules and timelines for obtaining transportation permits, resulting in regulatory conflicts.

Stage: 9

Storage, Accounting, Movement, and Testing

Current State

Operations involving the storage, movement, and testing of substances, materials, and ammunition are governed by various fragmented regulations — from occupational safety norms (Regulatory and legal acts on labor protection) to Ministry of Internal Affairs orders. Inventory is often maintained manually, and oversight of testing processes is inconsistent. There are no unified regulation outlining procedures for all internal manufacturing operations.

Stage: 10

Disposal of Explosives and Derivative Waste

Current State

The handling of explosive waste is governed by environmental and industrial legislation. The absence of specialized procedures for ammunition manufacturers leads to inconsistent (double) interpretations regarding classification, accounting, temporary storage, and disposal.

Stage: 11

Design and Operational Documentation

Current State

Existing requirements for technical support of the product are scattered and do not reflect the specific nature of military-purpose products. There is no approved list of mandatory design, operational, and process documentation required to accompany ammunition through all production, transport, storage, and transfer stages.

Stage: 12

Storage, Accounting, and Transportation of Finished Products

Current State

Activities related to the storage and accounting of finished military-purpose products fall under the regulations of the Ministry of Internal Affairs, State Labor Service, and internal instructions of the Ministry of Defense. There is no unified regulation defining the procedures for documentation, transportation, movement, and inventory of finished goods at the manufacturer’s storage sites. The fragmentation of applicable rules results in procedural confusion.

Stage: 13

Product Codification

Current State

Codification of military-purpose products is a mandatory step for assigning a unique identification number under the national or NATO system (NSN). The procedure is centralized, often paper-based, and multi-layered, creating delays in timely product registration. There is no mechanism for preliminary codification or a digital portal for submitting technical specifications. The current process does not support flexible handling of pilot batches or temporary product lines.

Stage: 14

Supplying Finished Products to State Customers, Military Units, and Other Structures. Partnerships

Current State

Mechanisms for supplying finished products to the Armed Forces of Ukraine, other defense units, state bodies, and subdivisions remain partially regulated. Contracting is governed by multiple legal acts and Ministry of Defense regulations, but there is still no unified system that accounts for deliveries under the State Defense Order (SDO) as well as through charitable, donor, or foreign assistance programs.

Furthermore, collaboration of manufacturers with research institutions, private defense firms, expert communities, and international partners through pilot deliveries, testing, or joint R&D is not clearly regulated.

Stage: 15

Military Representative Offices

Current State

Acceptance of military-purpose products is performed by representatives of the Ministry of Defense according to outdated regulations that do not reflect current forms of cooperation with private manufacturers. There is no unified procedure for interaction with military representatives, nor clarity on acceptance criteria, reporting formats, or the status of such representatives, which leads to conflicts. Additionally, a significant portion of products is manufactured without initial Ministry of Defense technical specifications or within pilot frameworks, which prevents official acceptance or approval by representatives.

Stage: 16

Production Safety Requirements

Current State

Safety at facilities manufacturing explosives and ammunition is governed by numerous regulations (Regulatory and legal acts on labor protection, MIA, State Emergency Service of Ukraine, State Labor Service instructions), which do not form a coherent system and often conflict with each other. There is no unified legal framework integrating fire, industrial, ecological, and physical safety requirements adapted to wartime conditions.

There are no specific rules for dual-use or mobile production units. Additionally, issues related to inspection frequency, enterprise management liability, and coordination with regulatory bodies remain underregulated.

Stage: 17

Accounting, Reporting, and Oversight

Current State

Companies involved in the production, storage, transportation, disposal, and sale of ammunition and explosives are subject to various regulations, including MIA Instruction No. 622, Regulatory and legal acts on labor protection 0.00-6.04-06, tax laws, and export control requirements. However, there is no unified reporting format for different government agencies, submission timelines for similar data are inconsistent, often duplicated, or contradictory. Recordkeeping is mostly manual and not integrated with national information systems. There is no single digital interface for manufacturers to submit reports to relevant authorities (Ministry of Defense, MIA, State Tax Service, SSECU, etc.).

Stage: 18

Enterprise Liquidation

Current State

There is no specialized procedure or requirements for the safe liquidation of enterprises engaged in explosives production. This creates potential risks to the environment, third parties, and for the accountability of leftover materials.

Lifecycle of Ammunition:

Manufacturing Enterprises

The private defense industry sector needs uniform rules of the game for all market participants and targeted regulation of the industry.

Current State

Current State

Current State

Current State

Current State

Currently, location requirements are defined by various industry-specific regulations, most of which are not adapted to the specifics of ammunition. Security requirements are often not integrated, and permits for storage and production are issued by different authorities.

Current State

Current legislation (the Law of Ukraine "On State Secrets" and SSU procedures) does not account for the production-specific needs of ammunition enterprises. The procedures are lengthy, and the criteria for obtaining access permits are non-transparent.

Current State

Current State

Transportation of explosives, precursors, and military-purpose products requires permits from the Ministry of Internal Affairs and route approvals. There is no unified document that sets out clear rules and timelines for obtaining transportation permits, resulting in regulatory conflicts.

Current State

Current State

The handling of explosive waste is governed by environmental and industrial legislation. The absence of specialized procedures for ammunition manufacturers leads to inconsistent (double) interpretations regarding classification, accounting, temporary storage, and disposal.

Current State

Current State

Current State

Current State

Current State

Current State

Current State

Current State

There is no specialized procedure or requirements for the safe liquidation of enterprises engaged in explosives production. This creates potential risks to the environment, third parties, and for the accountability of leftover materials.

Lifecycle of Ammunition:

Manufacturing Enterprises

The private defense industry sector needs uniform rules of the game for all market participants and targeted regulation of the industry.

Current State

Current State

Current State

Current State

Current State

Currently, location requirements are defined by various industry-specific regulations, most of which are not adapted to the specifics of ammunition. Security requirements are often not integrated, and permits for storage and production are issued by different authorities.

Current State

Current legislation (the Law of Ukraine "On State Secrets" and SSU procedures) does not account for the production-specific needs of ammunition enterprises. The procedures are lengthy, and the criteria for obtaining access permits are non-transparent.

Current State

Current State

Transportation of explosives, precursors, and military-purpose products requires permits from the Ministry of Internal Affairs and route approvals. There is no unified document that sets out clear rules and timelines for obtaining transportation permits, resulting in regulatory conflicts.

Current State

Current State

The handling of explosive waste is governed by environmental and industrial legislation. The absence of specialized procedures for ammunition manufacturers leads to inconsistent (double) interpretations regarding classification, accounting, temporary storage, and disposal.

Current State

Current State

Current State

Current State

Current State

Current State

Current State

Current State

There is no specialized procedure or requirements for the safe liquidation of enterprises engaged in explosives production. This creates potential risks to the environment, third parties, and for the accountability of leftover materials.

Етап 1:

Реєстрація підприємства