Ukraine Updates Cosmetic Products Safety and Notification Rules

Ukraine is proposing amendments to its cosmetic product regulations to strengthen safety and compliance requirements for cosmetic products

Compliance Analysis: Ukraine’s Proposed Amendments to Cosmetic Product Regulations

Ukraine is strengthening its cosmetic product regulations through two key draft measures: (1) amendments to the Technical Regulation on Cosmetic Products (approved by Resolution of the Cabinet of Ministers No. 65 of 20 January 2021) via Resolution No. 976 of 29 July 2026, and (2) amendments to the Procedure for the Notification (Submission) of Information on Cosmetic Products (approved by Order of the Ministry of Health No. 2147 of 18 December 2023) via a draft Order of the Ministry of Health. These amendments introduce stricter safety assessment requirements, extend transitional periods, and streamline notification procedures to align with EU standards.

1. Key Amendments to the Technical Regulation on Cosmetic Products

Regulation:

Resolution of the Cabinet of Ministers No. 976 of 29 July 2026 (amending Resolution No. 65 of 20 January 2021).

Key Changes:

1. Safety Assessment Requirements
   • The safety assessment of cosmetic products must be conducted by an expert holding a Master’s degree in specialty I2 (Medicine) or I8 (Pharmacy), or a related specialty included in a list approved by the Ministry of Health of Ukraine^{1, 2}.
   • This provision enters into force on 1 February 2027^{2, 1}.

1. Transitional Period Extension
   • The making available of cosmetic products placed on the market before 31 July 2027 (previously 3 August 2026) cannot be prohibited or restricted for non-compliance with the Technical Regulation^{1, 2}.
   • This extension applies to products already on the market before the amendments’ entry into force.

1. Entry into Force
   • The Resolution entered into force on 1 August 2026, except for the safety assessment qualification requirement (effective 1 February 2027)².

2. Key Amendments to the Notification Procedure for Cosmetic Products

Regulation:

Draft Order of the Ministry of Health (amending Order No. 2147 of 18 December 2023).

Key Changes:

1. Streamlined Notification Process
   • Removal of redundant requirements: No longer mandatory to submit graphic files of product labeling or photographs of packaging prior to market placement³.
   • Automated data exchange: Introduction of an open Application Programming Interface (API) for automated electronic data submission between the responsible person and the Electronic System for Notification³.
   • Ingredient identification: Allows manual entry of safe ingredients using international identifiers (INCI, IUPAC, CAS, EC)³.

1. Harmonization with EU Standards
   • The amendments aim to align Ukraine’s notification procedures with EU requirements, reducing administrative burdens and facilitating trade³.

1. Comment Period
   • The draft Order was open for public comments until 7 August 2026 (30 days from notification)³.

3. Regulatory Timeline and Compliance Deadlines

4. Legal Basis and Supporting Documents

• Primary Laws:
  • Law of Ukraine "On Technical Regulations and Conformity Assessment"^{1, 3}.
  • Law of Ukraine "On State Market Surveillance and Control of Non-Food Products"³.
• Relevant Notifications:
  • WTO/TBT notifications: G/TBT/N/UKR/351/Rev.1/Add.1, G/TBT/N/UKR/145/Add.2, G/TBT/N/UKR/299, G/TBT/N/UKR/263/Rev.1^{1, 3}.
• Final Texts:
  • Resolution No. 976 (29 July 2026):³(https://zakon.rada.gov.ua/laws/show/976-2026-%D0%BF#Text)².
  • Resolution No. 737 (4 June 2026):³(https://zakon.rada.gov.ua/laws/show/737-2026-%D0%BF#Text)⁴.

5. Stakeholder Engagement

• Comments Submission:
  • For the draft Order of the Ministry of Health, comments were accepted until 7 August 2026³.
  • For the draft Resolution of the Cabinet of Ministers, comments were accepted until 1 September 2026¹.
• Contact Authority:
  • Secretariat of the Cabinet of Ministers of Ukraine, Department of International Trade Policy.
  • Address: 12/2 Hrushevskoho Str., Kyiv 01008.
  • Email: ep@kmu.gov.ua | Tel: +(38 044) 256 65 07 | Website:³(https://www.kmu.gov.ua/)^{1, 3}.

Summary Answer

Ukraine’s proposed amendments to cosmetic product regulations introduce stricter safety assessment qualifications (effective 1 February 2027), requiring experts to hold a Master’s degree in Medicine or Pharmacy^{1, 2}. The transitional period for non-compliant products is extended to 31 July 2027^{1, 2}. Additionally, the notification process is streamlined through API integration and the removal of redundant documentation requirements, aligning with EU standards³. The Resolution No. 976 (29 July 2026) entered into force on 1 August 2026, while the draft Order of the Ministry of Health remains under review^{2, 3}. Stakeholders were invited to submit comments until 7 August 2026 (draft Order) and 1 September 2026 (draft Resolution)^{1, 3}. All cited sources (²,³,¹,⁴) are reflected in this analysis.

Sources

1. ↩ Draft Resolution of the Cabinet of Ministers of Ukraine “On Amendments to Resolution  of the Cabinet of Ministers of Ukraine No. 65 of 20 January 2021” (concerning Technical Regulation on cosmetic products) — imrd / directdoc https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN26/UKR392.docx
2. ↩ Draft Resolution of the Cabinet of Ministers of Ukraine “On Amendments to Resolution  of the Cabinet of Ministers of Ukraine No. 65 of 20 January 2021” (concerning Technical Regulation on cosmetic products) — imrd / directdoc https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN26/UKR392A1.docx
3. ↩ Draft Order of the Ministry of Health of Ukraine “On Approval of Amendments to the Procedure for the Notification (Submission) of Information on Cosmetic Products” https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN26/UKR395.docx
4. ↩ The draft Resolution of the Cabinet of Ministers of Ukraine “On Amendments to the Resolution of the Cabinet of Ministers of Ukraine No. 65 of 20 January 2021” (cosmetic products) https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN25/UKR351R1A1.docx