Ukraine Plans to Regulate Certain Food Contact Epoxy Derivatives

SafeGuardSHardgoodsJanuary 19, 2026

SG 007/26

Ukraine completes public consultation on the nation’s draft order concerning the use of certain epoxy derivatives in food contact materials (FCMs) and articles.

In December 2025, Ukraine’s Ministry of Health announced a 15-day consultation on its draft order ‘On approval of requirements for the restriction of use of certain epoxy derivatives in materials and articles intended to come into contact with food’ (the Draft Order). The Draft Order adopts Commission Regulation (EC) No. 1895/2005 on the restriction of certain food contact epoxy derivatives from the European Union (EU).

Key highlights of the Draft Order are summarized in Table 1.

Abbreviation	Name
I ‘General provisions’	Applies to food contact materials and articles, including active and intelligent materials and articles, which are manufactured using BADGE, BFDGE and/or NOGE Defines materials and articles as a) those made of plastic, b) those covered by surface coatings and c) adhesives Exempts 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’ Prohibits BFDGE and NOGE in the manufacture of materials and articles
II ‘Specific migration limit from BADGE and some of its derivatives’	≤ 9 mg/kg as the sum of the migration of BADGE, BADGE.H₂O (CAS 76002-91-0) and BADGE.2H₂O (CAS 5581-32-8), or ≤ 9 mg/6 dm² as the sum of the migration of these substances in specified applications ≤ 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), or ≤ 1 mg/6 dm² as the sum of the migration of these substances in specified applications

Table 1

Ukraine completed its consultation on January 3, 2026.

The Draft Order is intended to enter into force three months after its publication in the Official Gazette.

Abbreviation

Abbreviation	Name
BADGE (CAS 1675-54-3) and some of its derivatives	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

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