Ukraine Launched E-notification for Cosmetic Products
On December 1, 2025, the System for Electronic Notification (Provision) of Information on Cosmetic Products (the "System”) officially began to function. Notably, the notification procedure was approved by the Order of the Ministry of Health dated 18 December 2023 No. 2147 "On Approval of the Procedure for Notification (Provision) of Information on Cosmetic Products”[1] (the "Procedure”), but the System itself was launched only now.
The main goal of introducing the System is to ensure a transparent accounting process for cosmetic products and harmonisation with the EU acquis, namely Regulation (EC) No. 1223/2009. In addition, the System aims to create a mechanism for effective quality and safety control, which will provide consumers with enhanced safety and help Ukrainian businesses eliminate trade barriers and increase competitiveness for domestic manufacturers. [2]
The System is mainly designed for manufacturers and importers of cosmetic products, who must notify information about each product. To do this, the head of each manufacturer or importer company (specified in the Unified State Register of legal entities, individual entrepreneurs, and public organisations) or an individual entrepreneur must personally register their enterprise through the electronic cabinet of the recipient of services. After registration, they will have the opportunity to appoint authorised and contact persons who can provide all the necessary product data directly.
To successfully enter a product into the System, an authorised person must create a draft cosmetic product specifying information about the type of product, type of shade, purpose, country of origin, labelling, category, and formulation of the product/component, presence of nanomaterials and CMR substances, etc. Also, if necessary, it will be possible to make appropriate changes to the product information. The information about the product in the System should generally correspond to that contained on the label, but other data may be added. [3]
It is worth noting, however, that the system’s functionality is currently limited only to the basic capabilities necessary for notification. Its scope is expected to expand over time. In particular, notification is currently available only to responsible persons who are manufacturers or importers of cosmetics. Later, such information can be entered by proxy.
In addition, the Ministry of Health, state market surveillance bodies, and state organisations responsible for toxicological control of cosmetic products will have access to information in the System. The latter, in particular, will be able to provide doctors with data on the formulation of cosmetic products for patients’ treatment over time. Nevertheless, the Procedure clearly states that data constituting a trade secret cannot be extracted from the System.
Enterprises must notify information on cosmetic products already in circulation by August 3, 2026. This deadline is established by the Technical Regulations for Cosmetic Products adopted by the Resolution of the Cabinet of Ministers of Ukraine dated January 20, 2021, No. 65[4]. The Regulation stipulates that cosmetic products that were put into circulation before August 3, 2026, cannot be prohibited or restricted due to non-compliance with the requirements of the Technical Regulations.