Law No. 4839-IX: When Ukraine's New Market Surveillance Rules Apply

Law No. 4839-IX entered into force on May 3, 2026, but the main package of new market-surveillance rules is subject to separate transition periods.

Correction. Following a new fact-check, we have corrected the earlier interpretation: May 3, 2026 is not the effective date for every amendment introduced by Law No. 4839-IX.

When the changes take effect

01
May 3, 2026

The law entered into force. Certain amendments, including changes to the Law on General Safety of Non-Food Products, already apply.

02
one year after publication

The main set of amendments to Law No. 2735-VI: supply-chain, online-sales, inspection and new market-participant obligations.

03
three years after publication

Specific provisions concerning fulfilment service providers.

04
when ACAA enters into force for Ukraine

Certain EU market-surveillance cooperation and mutual-assistance mechanisms.

What already applies

Law No. 2736-VI on General Safety of Non-Food Products has a current revision dated May 3, 2026 based on Law No. 4839-IX. Among the practical changes, the penalty-payment procedure was clarified: a 15-working-day payment period applies, appeal-related timing is specified, and unpaid decisions may be submitted for enforcement.

What should not yet be treated as fully effective

The main amendments to Law No. 2735-VI on State Market Surveillance and Control of Non-Food Products are deferred. The Verkhovna Rada database shows a future revision based on Law No. 4839-IX dated May 2, 2027. Therefore, expanded online-market controls, new supply-chain duties and many new inspection mechanisms should not be described as already fully applicable.

What businesses should check now

Practical takeaway

For each obligation, businesses should check the specific provision of Law No. 4839-IX and its own effective date. UKRCERT can assist with reviewing or preparing a declaration of conformity for products in Ukraine.

Official sources: Law No. 4839-IX; Law No. 2736-VI; Law No. 2735-VI.

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