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Ukraine Consults Over Proposed Law on Packaging and Packaging Waste

SafeGuardSAutomotive, Hardgoods, Personal and Protective Equipment, Softlines, Toys and Juvenile ProductsMay 14, 2023

SG 57/23

Ukraine has informed the WTO of its intention to promulgate the nation’s draft law on packaging and packaging waste. The draft law is proposed to enter into force on the day following its publication.

On May 5, 2023, the World Trade Organization (WTO) circulated a notification from Ukraine on its draft law on packaging and packaging waste. The proposal, attached to WTO Document number 23-3204, details the legal, economic and organizational principles for packaging and packaging waste management to ensure a reduction of their negative impact on human health and the environment, create a system for collection and recycling of packaging waste and promote the transition to a closed-loop economy.

The draft law is based on Directive 2008/98/EC ‘Waste Framework Directive’ (WFD) and Directive 94/62/EC in relation to packaging and packaging waste in the European Union (EU). It:

  • Defines economic operators and their obligations
  • Establishes requirements for the introduction of packaging, goods in packaging and packaging markings, to limit the presence of lead, cadmium, mercury and chromium (VI) in circulation (see Table 1 below)
  • Requires a declaration of conformity (DoC) for packaging (if requested)
  • Details the requirements for extended producer responsibility organizations (EPROs)
  • Provides illustrative examples on what is and what is not considered as packaging (Appendix 2)
  • Sets minimum targets for packaging waste recycling by type of packaging material (Appendix 3)

The law is proposed to enter into force on the day following its publication (in the nation’s Official Gazette). With the exception of several clauses, the provisions would apply from January 1, 2024.

Highlights of the requirements for four heavy metals in packaging in the draft law are summarized in Table 1.

WTO Document No. 23-3204, May 5, 2023
Draft Law of Ukraine on Packaging and Packaging Waste

SubstanceScope1RequirementProposed Effective Date
Chromium (VI)
Packaging or packaging components1≤ 0.06% (sum)Three years from date of entry into force
≤ 0.025% (sum)Four years from date of entry into force
≤ 0.01% (sum)Not specified

1Exempts packaging made entirely of lead crystal

Table 1


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