Ukraine's Law on Food Contact Materials Aids EU Integration

On November 19, 2025, the Law of Ukraine "On materials and articles intended for contact with food” [1](the "Law”) entered into force. The Law was adopted in 2022, but to facilitate smooth adaptation, a three-year transition period was provided. The main purpose of the Law is to align Ukrainian legislation with the European Union’s requirements and standards applicable to materials and articles, in contact with food, as well as to reduce the risks to the citizens’ health when consuming food.

What "materials and articles” are concerned?

The legislator does not provide an exhaustive list of materials and articles covered by the Law. This is not surprising, given that food can come into contact with many things. However, the Law establishes several criteria for their precise identification:

1) they must be intended for contact with food;

2) they come into contact with food and were intended for this purpose;

3) they are reasonably expected to come into contact with food or transfer their constituents into food under normal or foreseeable conditions of use.

However, the new standards are precisely applicable to: equipment, inventory, containers, packaging, dishes, cutlery, intellectual materials, and articles (labels, films, stickers, etc.). In addition, special requirements can be applied to specific materials, such as adhesives, ceramics, cork, rubber, glass, metal, paper, cardboard, plastic, silicone, cellulose, wax, wood, etc.

At the same time, the subjects that are not covered by the Law are clearly established. These are antiques, protective coatings or shells for cheese and ready-to-eat meat products, and fruits (provided that these products can be consumed with this shell).

New requirements and what key stakeholders should pay attention to

First, an important milestone of the Law is the implementation of Good Manufacturing Practice (GMP) requirements, which become mandatory. From now on, market operators must establish, implement, and apply two systems: quality assurance and quality control. The first should take into account employees’ qualifications, knowledge, and skills, as well as the organisation of production and the quality of the raw materials required to meet the requirements. The second includes monitoring the achievement of Good Manufacturing Practice (GMP) goals.

In addition, market operators are now required to confirm compliance with legal requirements by preparing a written declaration of conformity. The declaration must accompany materials and articles at all stages of circulation, except for the stage of sale to the end consumer. Also, manufacturers and importers will have to submit information on the traceability of materials and articles, that is, they should be able to identify the capacity from which and to which materials and articles are supplied.

Innovations also affect labelling. Relevant materials and articles must necessarily include information about their use, manufacturer, traceability, and features. For example, goods must be accompanied by a special inscription "for contact with food”, "Do not eat!”  or more specific "coffee maker”, "wine bottle”, "tablespoon”, etc. In addition, a separate graphic sign was introduced to accompany materials and articles intended for contact with food.

This should be ensured, in particular, by a sufficient height of lowercase letters (at least 1.2 millimetres, and for inedible parts of materials and objects – 3 millimetres) and labelling in Ukrainian. Also, ink on materials and objects should not be transferred in any way to the surface of materials and objects that come into contact with the food product, in quantities that cause food contamination.

Special State Register: What is subject to mandatory registration?

The legislation provides for the creation of a new electronic state register, and the registration itself will be carried out by the Ministry of Health (MOH). The objects to be registered include substances and plastic recycling processes used in the production of materials and articles. Registration itself is for an indefinite period; the circulation of substances and materials without registration or in violation of it is prohibited.

To register an object, the applicant must first submit a package of documents, that includes an application, a registration dossier for the object and its resume. After the Ministry of Health is satisfied that the information is complete and reliable, it transfers it to an authorised person (a state-owned enterprise) to obtain a scientific and expert opinion on the facility’s safety (for payment under an agreement between the applicant and the authorised person). The term for preparing a conclusion is six months, but in case of complexity of the object, the term can be extended for another six months. After that, the Ministry of Health has one month to make a decision.

The decision on state registration will determine the conditions for using the item. These decisions and their conditions, however, may be changed or canceled altogether if new information emerges that may indicate a potential food threat. In this case, a second scientific examination should be carried out.

Liability for violation of the requirements of the Law

The Law assigns the functions of state control to the State Service of Ukraine for Food Safety and Consumer Protection. Violation of the requirements for materials and articles intended for contact with food entails a fine: for legal entities in the amount of 15 minimum wages, and for individual entrepreneurs – 10 minimum wages, which as of November 2025 is UAH 120 thousand and UAH 80 thousand, respectively.

General conclusions

The Law represents a significant step in Ukraine’s EU alignment and imposes new requirements on Ukrainian businesses. Key compliance priorities include:

• Reviewing and updating labelling to meet new standards
• Monitoring adoption of new legislation in respect of state registration of substances and processes. As soon as the relevant legislation is adopted, the registration shall be performed. 
• Preparing declarations of conformity for materials and articles 
• Implementing GMP quality assurance and control system