On May 28, 2020, the Ukrainian Ministry of Economic Development, Trade and Agriculture notified the World Trade Organization (WTO) of a draft law on food contact materials (FCMs) and articles (FCAs). SGS reports that the law is modeled on a number of pieces of existing food contact legislation from the EU and includes provisions on (i) general requirements and safety, (ii) specific measures that could be adopted for 17 groups of materials and articles, (iii) requirements for recycled plastics, (iv) requirements for declarations of compliance as well as traceability and labeling, and (v) good manufacturing practices. Until the country adopts specific rules related to the 17 included groups of materials and articles, the draft law allows for use of FCMs and FCAs that have been approved in the EU.

Comments on the draft law and WTO notification are being accepted until July 27, 2020. It is unclear when the draft law would then be adopted, however, it would enter in force six months following its adoption.

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Chemical Watch (January 7, 2921). “Ukraine proposes draft law on chemical safety.”

SGS (June 3, 2020). “Ukraine Issues Draft Law on Food Contact Materials and Articles.”

Chemical Watch (June 2, 2020). “Ukraine proposes restriction on CMRs in FCMs.”


WTO (May 28, 2020). “Notification – Ukraine – Materials and articles intended for direct or indirect contact with foodstuffs.”

Ministry of Economic Development, Trade and Agriculture (May 21, 2020). “Draft Law of Ukraine “On Requirements for Materials and Items in Contact with Foodstuffs.” (in Ukranian)