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Ukraine Regulates Food Contact Materials and Articles

SafeGuardSHardgoodsDecember 01, 2022

SG 135/22

Ukraine has issued a new piece of legislation on food contact materials and articles. The new law entered into force on November 20, 2022, and many of the provisions will apply from November 19, 2025.

On November 19, 2022, Ukraine issued Law No. 2718-IX of November 3, 2022 ‘On Materials and Articles Intended to Come into Contact with Food’ in the Voice of Ukraine (Голос України  - No. 236). This comprehensive piece of legislation contains elements from several pieces of legislation on food contact materials and articles from the European Union (EU):

Highlights of Law No. 2718-IX on food contact materials and articles are summarized in Table 1

Section to Law No. 2718-IXHighlight
Section I
'General Provisions'
  • Scope: Food contact materials (FCM) and articles
    • Exemption
      • Antiques
      • Protective coatings or coverings such as those that cover the skin of cheese, ready-to-eat meat products or fruits, which form part of the food and may be consumed together with food
      • Fixed public or private water supply equipment
  • Provides terms and definitions
  • Defines powers to government agencies
Section II
Requirements for Materials and Articles
  • FCM and articles to be manufactured in compliance with Good Manufacturing Practice (GMP – see Section 5 for details)
  • General safety requirements
  • Labeling, advertising and presentation of materials and articles must not be misleading
  • General requirements for active and intelligent materials and articles
  • Special requirements may be established for 18 groups of FCM and articles (see Table 2 below) – these may include a positive list or permitted substances, overall migration limits (OML), specific migration limits (SML), compliance checking and tests, traceability and a written declaration of compliance (DoC)
  • Use of recycled plastics is allowed provided these are obtained through a state-registered plastic recycling process
Section III
‘State Registration of Articles’
  • Details the requirements and procedures for state registration of articles
Section IV
‘Marking, Declaration of Conformity and Ensuring Traceability of Materials and Articles’
  • Details the labeling information to be accompanied with materials and articles which are not yet in contact with food when placed on the market, including the words ‘for food contact’, or a special designation regarding their use, such as ‘coffee maker’, ‘wine bottle’, or the glass/ fork symbol (Appendix I)
  • Details the labeling information for active and intelligent materials and articles or parts thereof whenever they are perceived as edible with the words ‘Don’t Eat’ and always where technically possible, with the ‘Don’t Eat’ symbol (Appendix II)
  • Declaration of conformity (DoC) for materials and articles subject to special requirements specified in Article 8
  • Ensures traceability of FCM and articles at all stages in order to facilitate control, recall of defective products, consumer information and the attribution of responsibility
Section V
‘Good Manufacturing Practice’
  • Details the requirements for GMP, including:
    • Quality assurance and quality control systems and documentation
    • Use of printing inks (Appendix 3)
    • Requirements for the quality assurance of plastic recycling processes (Appendix 4)
Section VI
‘State Control Responsibility’
  • Defines powers to government agencies

Table 1

The new law contains several important dates:

  • November 20, 2022, for date of entry into force – the day following its publication
  • November 19, 2025, for provisions in the law other than those indicated below – three years from the date of publication
  • November 20, 2022, for clauses 2, 4 and 5 to Section VII ‘Final and Transitional Provisions’ (except for a few paragraphs under clause 4 which will become effective on November 19, 2025)
Entry No.Food Contact Material
1Active materials and articles
2Intelligent materials and articles
8Ion-exchange resin
9Metals and alloys
10Paper and cardboard
12Printing inks
13Regenerated cellulose
16Varnishes and coatings

Table 2

SGS technical experts have extensive knowledge and testing experience in materials and articles in contact with food. They work to ensure that your products meet the appropriate regulations for food contact materials, paving the way for compliance. From overall migration tests to expert advice on emerging regulations, compliance issues and documentation review, SGS is the partner to trust. In the end, it’s only trusted because it’s tested. Discover more on our website and read our brochure.

For enquiries, please contact:

Dr. Hingwo Tsang
Global Information and Innovation Manager
t: +852 2774 7420

© SGS Société Générale de surveillance SA- 2022 - All rights reserved - SGS is a registered trademark of SGS Société Générale de surveillance SA. This is a publication of SGS, except for 3rd parties’ contents submitted or licensed for use by SGS. SGS neither endorses nor disapproves said 3rd parties contents. This publication is intended to provide technical information and shall not be considered an exhaustive treatment of any subject treated. It is strictly educational and does not replace any legal requirements or applicable regulations. It is not intended to constitute consulting or professional advice. The information contained herein is provided “as is” and SGS does not warrant that it will be error-free or will meet any particular criteria of performance or quality. Do not quote or refer any information herein without SGS’s prior written consent.

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