The draft proposal, notified to the World Trade Organization (WTO) on 3 July 2026, includes two significant measures: extending the transitional period for existing cosmetic products and clarifying the qualification requirements for cosmetic safety assessors. Stakeholders may submit comments on the proposal until 1 September 2026.
Background to Ukraine’s cosmetic legislation
Ukraine’s Technical Regulation on Cosmetic Products, adopted in 2021, closely follows the structure and principles of the EU Cosmetics Regulation (EC) No. 1223/2009.
The regulation introduced many of the compliance requirements already familiar to companies operating in the European Union, including:
- appointment of a Responsible Person;
- preparation of a Product Information File (PIF);
- completion of a cosmetic safety assessment and safety report;
- electronic product notification before placing products on the market.
The proposed amendment does not alter these core obligations but would provide additional time for companies that are still transitioning to the new framework.
Additional time for compliance
One of the most important proposed changes is the extension of the current transitional period.
Under the draft amendments, cosmetic products that were already legally placed on the Ukrainian market before the Technical Regulation became applicable would be allowed to remain on the market until 31 July 2027, rather than the current deadline of 3 August 2026.
During this extended period, these products could continue to be supplied even if they do not yet fully comply with the requirements of the Technical Regulation. The proposal is intended to give manufacturers and importers additional time to complete regulatory updates while reducing the risk of market disruption.
New clarification on safety assessor qualifications
The draft also provides greater clarity regarding the professionals who may perform cosmetic safety assessments.
According to the proposal, the safety assessment required under the Technical Regulation must be carried out by a qualified safety assessor holding a Master’s degree in Medicine or Pharmacy, or another related qualification recognised by the Ukrainian Ministry of Health.
This clarification aligns Ukraine’s requirements more closely with the scientific expertise expected under the European cosmetic regulatory system, helping to ensure that product safety assessments are performed by appropriately qualified professionals.
What the proposal means for cosmetic manufacturers
If adopted, the amendments would provide companies supplying the Ukrainian market with greater flexibility to complete their compliance activities.
Manufacturers that are still updating formulations, labelling, technical documentation or Product Information Files would have almost one additional year to complete these tasks before the transitional period expires.
The clarification of safety assessor qualifications also provides greater legal certainty for companies selecting experts to prepare cosmetic safety reports.
Consultation remains open
The proposed amendments have not yet entered into force and remain subject to public consultation.
Businesses with interests in the Ukrainian cosmetics market may submit comments to the Ministry of Health until 1 September 2026. Following the consultation, the government will review the feedback before publishing the final version of the amendments.
