New Law on Organic Production: What Should Operators Prepare For?
On 30 June 2026, the Verkhovna Rada of Ukraine adopted the Law of Ukraine "On State Regulation of Organic Production, Circulation and Labelling of Organic Products” (the "Law”), facilitating Ukraine’s European integration.[1] The purpose of adopting the Law is to harmonise Ukrainian legislation with updated EU legislation on the regulation of organic production. The need to adopt the Law is largely due to the fact that 90% of Ukrainian organic products are exported to EU countries.[2]
What product categories are covered by the Law?
The scope of the Law covers live animals or agricultural products that are not subject to processing, in particular seeds and planting material, agricultural products that are processed and are food products, feed and a number of other products that meet the conditions of the Law (beeswax, yeast, salt, essential oils, natural resins, etc.). The production and circulation of these categories of products are subject to certification.
The Law does not apply to products intended for own consumption, perfumery and cosmetic products, medicines, products made from aquatic biological resources that belong to animals, and hunting products, as well as to the activities of public catering establishments. In addition, an important innovation was the exclusion from mandatory certification of processed agricultural products that are not food products (for example, technical fats, bioethanol, products for the pharmaceutical industry, etc.). [3]
Mandatory certification: who is affected by the new rules?
In addition to the scope of application of the Law, the rules for certification of organic products have also been updated. From now on, the certification requirement also applies to operators who sell organic or in-conversion products directly to the end consumer. This obligation may not be imposed provided that packaged products are sold in the presence of the operator and the end consumer. In addition, such a business entity must not carry out production, storage (except for storage associated with the place of sale) or import of such products.
Certification is carried out by authorised bodies ("control (certification) body”) in accordance with the procedure approved by the Cabinet of Ministers of Ukraine. The operator chooses a control (certification) body at its own discretion and concludes a certification agreement with it. The certificate is valid for 15 months from the date of its issuance. The grounds for refusing to issue a certificate are limited to (1) the establishment of a significant or critical non-compliance with the Law; (2) the detection of inaccurate information during the verification of documents. [4]
The Law introduces a new term, "group of operators”,[7] and therefore now provides for the possibility of group certification of manufacturers and sellers.
Permitted substances and exemptions for organic producers
The Ministry of Agrarian Policy and Food[8] will be empowered to approve the list of permitted substances and products, which includes plant protection products, fertilisers, feed materials and additives, disinfectants for livestock, crop production and processing facilities, as well as food and technological additives. The use of these items is allowed only under the conditions of compliance with the law, mandatory state registration of pesticides and agrochemicals, and the absence of official prohibitions on their use. [9]
The new rules provide for the application of exceptions to the requirements for organic production. The State Food and Consumer Service may approve individual exceptions for operators, in particular regarding the use of non-organic animals, aquaculture animals, and protein feeds for pigs or poultry, tethering livestock, carrying out certain veterinary procedures, etc.
Separate rules will apply to inorganic planting material. The control (certification) body may allow its use for one season for a specific farm if there are no organic analogues or materials of the conversion period on the Ukrainian market. If there are no necessary varieties or ingredients on the market at all, the State Food and Consumer Service has the right to issue a general permit for all operators.[10]
State control and sanctions: what can operators expect?
The activities of the operator, a group of operators, are still subject to annual inspection. The main difference from the current legislation was the authorisation of control (certification) bodies to carry out state control measures. The period between inspections, including on-site visits to operators’ facilities, is 24 months, if (1) no instances of non-compliance affecting the authenticity of products have been identified as a result of government control measures in the last three years; (2) based on the results of the operator’s risk assessment, the group of operators is assigned to an insignificant degree of risk.[11]
Stricter sanctions have also been established for violations and non-compliance with the requirements of the law: a fine of up to eight minimum wages (as of July 2026 – UAH 69,176) for legal entities, and for sole proprietors – up to five minimum wages (as of July 2026 – UAH 43,235). For repeated violations during the year, fines are increased to twenty-four minimum wages (as of July 2026 – UAH 207,528) for legal entities and up to sixteen minimum wages for sole proprietors (as of July 2026 – UAH 138,352).[12]
Updated list of state registers
The Law provides for updating the list of state registers in the field of organic production. The Law provides for the Register of Operators, the Register of Authorised Control (Certification) Bodies, the Register of Organic Planting Material, the Register of Organic Animals, as well as a specially created Register of Organic Aquaculture Animals.
The new Register, like the rest, will be maintained in electronic form, registration in it is free of charge, and the basis for entering information will be an application for entry, an application with updated information and documents submitted through the electronic cabinet of the relevant registers by an operator or a group of operators with a qualified electronic signature. [13]
Conclusions
Therefore, the new Law is part of the package of European integration legislation, which increases the requirements for Ukrainian enterprises that sell their products as organic. Although the Law as a whole will enter into force only on 21 July 2029, operators should already familiarise themselves with the new rules in order to adapt the production and circulation of goods and prepare proper documentation.
[1] https://itd.rada.gov.ua/billinfo/Bills/CardByRn?regNum=13204-1&conv=9
[2] Explanatory note to the draft Law
[3] Law, Article 3
[5] Subparagraph 2 of paragraph 3 of the Regulation on the State Service of Ukraine for Food Safety and Consumer Protection
[6] Law, Article 23
[7] Law, Clause 10 of Part 1 of Article 1
[8]The relevant powers were assigned to the Ministry of Economy, Environment, and Agriculture of Ukraine. Pursuant to Cabinet of Ministers Resolution No. 963, the Ministry of Economy, Environment, and Agriculture was once again divided into the Ministry of Economy and Environment of Ukraine and the Ministry of Agrarian Policy and Food of Ukraine, and draft regulations on the respective ministries, detailing their powers, must be submitted within two weeks. As of 24 July 2026, there are no regulations governing the Ministry of Agrarian Policy and Food of Ukraine. Historically, these functions were the responsibility of the Ministry of Agrarian Policy and Food of Ukraine.
[9] Law, Article 15
[10] Law, Article 16
[11] Law, Articles 34, 36
[12] Law, Article 39
[13] Law, Article 28