Germany’s Ministry of Transport, in an updated clarification from September 11, 2026, offers Ukrainians returning with a German-registered car two options: deregister the vehicle electronically or obtain transit plates under section 45 of the FCFAU regulation. Both options create a conflict with Ukrainian customs legislation, and the clarification does not provide a clear answer about where exactly to change the plates.
Why you cannot deregister a car in Germany before leaving
Deregistering a vehicle in Germany means it can no longer participate in road traffic in that country. Therefore, to return to Ukraine, a valid German registration is required — essentially, the car must be exported from Germany on German plates, and advance deregistration is not possible.
A deregistration request can be submitted to the last registration authority that serviced the vehicle, including in electronic form — in which case deregistration occurs automatically. This is the first option proposed by the Ministry of Transport: remote deregistration. However, it remains unclear at what point and in which country’s territory this should be done.
The problem at the Ukraine border
If you enter Ukraine on German plates, for example, at the Poland border, difficulties arise with Ukrainian border and customs authorities. Entry on foreign registration places the car in a temporary customs regime, which allows a period — up to one month — for movement, after which the car must be cleared through customs.
In other words, you cannot simply enter Ukraine on German plates and leave it at that: you will have to either clear the car through customs or leave again. A conflict arises: Germany is responsible only for its own territory and requires movement on German plates within the country, but Ukrainian legislation imposes its own requirements at the border itself. It is unclear from the clarification where exactly to remove German plates and attach Ukrainian ones — at the border, in Poland, or already on Ukrainian territory.
Alternative — transit plates
The second option offered by the Ministry of Transport is to apply for transit plates according to section 45 of the FCFAU regulation. With such plates, you can cross borders between countries, and in principle this option has fewer problems than leaving on permanent German registration.
However, here too there is no clarity about how Ukrainian customs will view it. It is possible that the plates will have to be changed at the border, in a buffer zone, so as not to violate the legislation of either country — or Ukraine may allow the car through on transit plates without additional requirements. Of the two options, transit plates appear to be a more adequate solution than leaving on a permanent German registration.
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