From 19 November 2025, Ukraine started applying new requirements to materials and articles intended to come into contact with food. For certain categories of packaging, plastics, coatings, adhesives, printing inks and other materials, a written declaration of conformity with supporting documentation is required.
The new rules are introduced by Law of Ukraine No. 2718-IX “On Materials and Articles Intended to Come into Contact with Food” and Order of the Ministry of Agrarian Policy No. 1743 dated 2 October 2023.
When the new requirements started to apply
Law No. 2718-IX was published on 19 November 2022. Under its transitional provisions, the main requirements started to apply three years later — on 19 November 2025.
Order No. 1743 sets the requirements for a written declaration of conformity for materials and articles intended to come into contact with food, as well as the list of documents supporting the information stated in the declaration.
Which materials are affected
The requirements apply to market operators dealing with materials and articles intended to come into contact with food. The list includes, among others:
- active and intelligent materials;
- adhesives, varnishes and coatings;
- ceramics, glass, rubber, cork, wax and wood;
- metals and alloys;
- paper and board;
- plastics;
- printing inks;
- regenerated cellulose, silicone and textiles.
Materials and articles, as well as products from intermediate stages of their production, must be accompanied by a declaration at all stages of circulation, except at points of sale to final consumers. Special rules apply to certain groups of products.
What the written declaration should contain
The written declaration of conformity must identify the market operator issuing the document, as well as the manufacturer or importer of the materials and articles.
The declaration should also include:
- the name and identification of the material or article;
- a statement of compliance with legal requirements;
- reference to good manufacturing practice;
- conditions of use;
- categories of food intended to come into contact with the material;
- duration and temperature conditions of processing or storage;
- the surface-area-to-volume ratio used to verify compliance with migration limits.
If you need to prepare a document for your product, see our Declaration of Conformity service.
Additional data for active, intelligent and plastic materials
For active and intelligent materials, the declaration should contain information on substances subject to legal restrictions, purity criteria, the name and quantity of substances released by the active component, and data on the suitability and effectiveness of the material.
For plastic materials and articles, information is required on substances or degradation products for which restrictions or specifications are established. Such data may be based on test results or theoretical calculations of specific migration limits.
Which documents support the declaration
The market operator must keep supporting documentation in paper or electronic form. For active and intelligent materials, plastics, ceramics, varnishes and coatings, additional documentation may include information on:
- rules and conditions of laboratory testing;
- results of migration limit checks;
- the name and address of the laboratory;
- evidence of material safety;
- justification of compliance with legal requirements;
- technical data and traceability of the material.
These documents must be provided to the competent authority upon request. Therefore, the declaration should not be a formal file without an evidence base: it should be supported by test reports, technical documentation and traceability.
When the declaration should be updated
The declaration should be reviewed or updated if significant changes in production affect the migration of substances from materials or articles. It should also be reviewed when new scientific information becomes available.
For businesses, this means that the declaration should be linked to the current composition of the material, raw material supplier, production technology and test results. If the formulation, coating, adhesive or conditions of use change, the documentation package should be reviewed.
Why this matters for manufacturers and importers
The new requirements affect packaging manufacturers, material importers, food producers and companies using food contact materials in production.
The absence of the required documentation may create risks during inspections, supplies to retail chains or export operations.
How UKRCERT can help
UKRCERT helps manufacturers and importers to:
- determine whether a written declaration is required;
- check the availability of necessary test reports;
- prepare a technical documentation package;
- assess compliance of materials with Ukrainian and EU requirements;
- prepare declarations and supporting documents.
Sources: Law of Ukraine No. 2718-IX, Order No. 1743, Ukrainian Parliament notice.