Law No. 4839-IX amended the Law of Ukraine “On Placing Construction Products on the Market”. For manufacturers and importers, the key issue is practical compliance: documents, electronic notices and the date when products were placed on the market must be controlled more carefully.
| No. | Before | Now | Practical meaning |
|---|---|---|---|
| 1 | The transition between the previous Technical Regulation for construction products and the new law was less clear for businesses. | Until 31 December 2025, manufacturers could choose whether to apply Law No. 850-IX or the previous technical regulation. | Manufacturers could plan the transition to the new rules without abruptly stopping supplies. |
| 2 | It was not separately clarified how to treat products placed on the market under the old rules before the end of the transition period. | Products placed on the market before 31 December 2025 under the previous technical regulation may not be restricted or prohibited solely because they do not comply with the new law — until 31 December 2027. | This is important for stock, distributors and imported batches that were already lawfully placed on the market. |
| 3 | Market surveillance orders for construction products did not have such a detailed digital delivery procedure. | Documents may be sent through the Unified State Electronic System in the Construction Sector, by email or by registered post. | Businesses must monitor their electronic cabinet, email stated in the declaration of performance and registry data. |
| 4 | The date of receipt of documents was not so clearly linked to electronic delivery. | The law clarifies how the receipt date is determined, including by electronic system data or postal operator data. | Response deadlines to market surveillance requirements may run from that date. |
| 5 | The wording on corrective measures was less precise. | The focus is on products covered by a standard or technical assessment conclusion, which do not match the declared performance and create a risk to basic requirements for buildings and structures. | The main business risk is inconsistency between the declaration of performance, technical documentation and actual product characteristics. |
What manufacturers and importers should check
Before supplying construction products, businesses should verify whether the declaration of performance is properly prepared, whether data in the electronic construction system is up to date, whether marking matches the documents, whether technical documentation is available and, for imported products, whether Ukrainian translations of documents are prepared correctly.
The practical conclusion is simple: documentation for construction products should be prepared before supply, not after a market surveillance request. This reduces the risk of suspended sales, claims against the importer or requirements to remove products from the market.
Source: Law of Ukraine No. 4839-IX on the Verkhovna Rada website