SG 048/26
Ukraine notifies the World Trade Organization (WTO) of its new law on epoxy derivatives in food contact materials (FCM).
In February 2026, the WTO announced Ukraine’s adoption of Order of the Ministry of Health of Ukraine No 55 ‘On approval of the Requirements for Restricting the use of Certain Epoxy Derivatives in Materials and Articles Intended to Come into Contact with Food’ (the Order).
What does this regulation require?
Order No 55 of January 15, 2026 (Order No. 55/2026) regulates the use of BADGE and its derivatives, BFDGE and NOGE in food contact materials (FCM) and articles, including active and intelligent materials and articles that are plastics, and those covered with a coating or adhesive.
- Prohibits BFDGE and NODE
- Sets a limit of ≤ 9 mg/kg as the sum of the specific migration of BADGE, BADGE.H2O (CAS 76002-91-0) and BADGE.2H2O (CAS 5581-32-8), and ≤ 9 mg/6 dm² as the sum of the specific migration of these substances in specified applications (excluding food contact plastics intended for contact or already in contact with baby food)
- Sets a limit of ≤ 1 mg/kg as the sum of the migration of BADGE.HCl (CAS 13836-48-1), BADGE.2HCl (CAS 4809-35-2) and BADGE.H2O.HCl (CAS 227947-06-0), and ≤ 1 mg/6 dm² as the sum of the migration of these substances in specified applications (excluding food contact plastics intended for contact or already in contact with baby food)
The requirements above do not apply to containers or storage tanks with a capacity of more than 10,000 liters, including any associated or connected pipelines, when covered by ‘heavy-duty coatings.’
| Abbreviation | Name |
|---|---|
| BADGE (CAS 1675-54-3) | 2,2-bis(4-hydroxyphenyl)propane bis(2,3-epoxypropyl) ether |
| BFDGE (CAS 39817-09-9) | Bis(hydroxyphenyl)methane bis(2,3-epoxypropyl) ethers |
| NOGE | Novolac glycidyl ethers |
Who is impacted?
The new law affects economic operators across the FCM and article supply chain, including manufacturers, importers and distributors.
When does it apply?
Order No 55/2026 will become effective on May 17, 2026.
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