Protecting fuel infrastructure during wartime, especially in frontline territories, does not have a single universal solution. Gas stations, oil depots, and logistics hubs remain vulnerable to attacks, while communities must continue to receive fuel even after losing stationary facilities.
According to the data provided in the column, in just half a year, more than 300 gas stations were damaged or destroyed in Ukraine as a result of Russian attacks. The problem is most acute in frontline regions, where there are already communities that have completely lost their stationary refueling points.
At the same time, there is no nationwide fuel shortage. The problem arises at the final stage—physically delivering and legally dispensing fuel directly within the community where the stationary gas station no longer operates.
Under such conditions, residents are forced to travel dozens of kilometers to the nearest gas station, transport fuel in canisters, and local authorities have to independently seek temporary ways to supply municipal enterprises and critical services.
Not a Single Solution, but Legal Scenarios
FEBA’s position is that mobile gas stations cannot and should not be considered as a universal replacement for stationary fuel infrastructure.
This is only one of the possible tools that, under certain conditions, can be used to supply fuel to a community after the loss of stationary facilities.
The state’s task is to create legislative opportunities for various scenarios so that regional military administrations, communities, and legal businesses can choose a solution that will actually work in the respective territory, depending on the specific security situation.
For one community, such a solution may be the restoration and additional protection of a stationary gas station. For another—an automated station, dispersion of reserves, or alternative logistics. And where stationary infrastructure is destroyed and cannot be quickly restored, one of the temporary options can be a mobile refueling point.
That is why the discussion regarding PazS should not be reduced to the question of “for” or “against” mobile refueling points.
The issue is much broader: what legal mechanism will a community have to supply fuel to the SES, ambulances, municipal services, generators, transport, the population, and businesses if its stationary fuel infrastructure is destroyed?
Current Regulations Do Not Account for the Realities of War
The column draws attention to a legal collision that currently effectively blocks one of the possible scenarios.
Current legislation is built primarily around the stationary model of retail fuel trade: the license is tied to a specific retail location. At the same time, legislation already provides for the concept of a mobile excise warehouse and allows the transportation of fuel by vehicles.
However, the current model does not allow transforming such a vehicle into a temporary legal point of retail fuel dispensing for the population.
Therefore, a separate decision by local authorities is not enough for a PazS to operate. A direct legislative norm is needed to define where, when, by whom, and under what conditions such a mechanism can be applied.
Legalizing the Mechanism Means Strengthening, Not Weakening Control
FEBA consistently emphasizes: this is not about permitting spontaneous fuel trade from “barrels” across all of Ukraine.
A potential special regime must be targeted and limited—for designated frontline and high-risk territories where the stationary network is lost or its operation has become dangerous.
Operating in such a regime must be restricted to currently licensed operators, and every liter of fuel must remain within the system of state control: excise accounting, RRO and fiscal receipts, confirmed origin and quality of fuel, metrological and fire safety requirements.
Mobility in this case should be a safety tool rather than a way to avoid control: the operating location may change according to the situation, but fuel accounting and its digital footprint must remain unchanged.
PazS is Only One Component of Fuel Resilience
At the same time, mobile refueling points do not solve the problem comprehensively.
For frontline territories, a broader set of solutions is necessary: protection of stationary gas stations and oil depots, development of automated stations, dispersion of reserves, backup logistics routes, insurance for employees and equipment, compensation for war losses, the ability to reserve critically necessary personnel, and separate tax mechanisms for actually destroyed and non-operational gas stations.
A separate problem remains the payment of the advance corporate income tax payment for a gas station that has actually ceased operations due to an attack. The Association’s position is that for the period of restoration of such a facility, there should be a possibility to suspend the payment of the advance contribution without having to give up the license and go through the entire procedure of obtaining it again.
The task today is not to find one universal solution for all frontline territories. The task is to create a legal set of tools that will allow each region to choose the safest and most practically feasible fuel supply scenario.
After all, in wartime conditions, access to fuel is not just a matter of the fuel market’s operation. It is the operation of emergency services, generators, water utilities, municipal transport, businesses, evacuation, and the community’s ability to continue functioning after another attack.
