Law No. 4839-IX Has Entered into Force: What Already Applies to Business
On May 3, 2026, Law of Ukraine No. 4839-IX entered into force, aiming to adapt Ukraine's market surveillance and technical regulation system to European Union approaches.
Some requirements, including those related to e-commerce, importers, authorised representatives and certain supply chain participants, are subject to transition periods. However, several practically important changes already apply: the procedure for payment and enforcement of penalties has been updated, digital interaction between businesses and market surveillance authorities has been clarified, and transition rules for construction products have been extended.
1. General Safety of Non-Food Products
The Law of Ukraine “On General Safety of Non-Food Products” has been updated in relation to liability for product safety violations.
- A precise deadline for payment of administrative penalties has been established: 15 working days from receipt of the market surveillance authority's decision (Article 15).
- A penalty decision is expressly defined as an enforcement document. If the penalty is not paid voluntarily within the established period, it may be enforced by the State Enforcement Service (Article 15).
- If an economic operator appeals the decision, the obligation to pay arises after a court or the head of the market surveillance authority leaves the decision against the business. In that case, the same 15-working-day payment period applies (Article 15).
- The term “restrictive (corrective) measures” has been replaced throughout the law with “corrective measures” (Section I, paragraph 2 of Law No. 4839-IX)).
2. Technical Regulations and Conformity Assessment
The law also amends the Law of Ukraine “On Technical Regulations and Conformity Assessment”.
- New terms have been added: “product supply chain” and “supply of products” (Article 1).
- The definition of “product” has been clarified (Article 1).
- Publication rules for technical regulations have been changed: technical regulations and related conformity assessment procedures must be published in the Official Bulletin of Ukraine and placed on the official website of the Verkhovna Rada of Ukraine (Article 19).
- When technical regulations are registered in the relevant database, information must be included about the EU legislation on which those regulations were based (Article 23).
- References to the rights of subsidiaries have been removed from several conformity assessment provisions (Articles 32, 34, 35, 41, 42-1).
3. Construction Products
A separate set of changes concerns the Law of Ukraine “On Making Construction Products Available on the Market”.
- The procedure for digital interaction between market surveillance authorities and businesses has been specified. Administrative documents may be sent through the Unified State Electronic System in the Construction Sector, by email, or by registered mail with delivery confirmation (Article 42).
- The date on which a business receives such documents is now clearly determined, including by the electronic delivery record in the user's account or by the date indicated by the postal operator (Article 42).
- The transition period for construction product manufacturers has been extended: until December 31, 2025, manufacturers could choose whether to apply the new law or the previous Technical Regulation for construction products (Section VIII, paragraph 3-1).
- Until December 31, 2027, construction products may not be restricted on the market if they comply with the previous technical regulation and were placed on the market before December 31, 2025 (Section VIII, paragraph 3-1).
4. Powers of the Electronic Communications Regulator
The law expands the functions of the National Commission for State Regulation in the Electronic Communications Sector. Its tasks now include cooperation with state market surveillance authorities and customs authorities to prevent violations of non-food product safety legislation (Article 4).
What Businesses Should Do
Companies that manufacture, import or sell products in Ukraine should review their internal procedures for receiving market surveillance orders, response deadlines, appeal procedures and control of technical documentation.
Particular attention should be paid to products subject to technical regulations, as well as to construction products for which separate transition rules apply.
Source: Law of Ukraine No. 4839-IX on the Verkhovna Rada website