On June 17, 2026, the World Trade Organization (WTO) circulated Technical Barriers to Trade (TBT) Committee notification G/TBT/N/UKR/351/Rev.1/Add.1 (symbol 26-4419). Ukraine notified that its Cabinet of Ministers adopted Resolution No. 737 on June 4, 2026, amending the Technical Regulation on Cosmetic Products approved by Resolution No. 65 of January 20, 2021.
The resolution was officially published on June 13, 2026 and enters into force six months after publication, i.e., on December 13, 2026. The amendment focuses on setting tiered market-placement transition periods for cosmetic products that "do not meet the requirements of the Technical Regulation," depending on the product situation. CIRS Group has compiled and summarized the core contents of this notification for your reference.
Background
Ukraine's core instrument for cosmetic regulation is the Technical Regulation on Cosmetic Products, approved by Cabinet Resolution No. 65 of January 20, 2021, which is structurally aligned with the EU Cosmetics Regulation (EC) No 1223/2009. It requires cosmetic products to complete electronic notification, undergo safety assessment, establish a Product Information File (PIF) and safety report, and have a Responsible Person / domestic agent fulfill the relevant obligations before being placed on the market.
Due to factors such as martial law, the implementation timeline of the Technical Regulation had previously been adjusted. Resolution No. 737 further amends Resolution No. 65, focusing on clarifying the market-placement transitional arrangements-by product situation-for cosmetic products that do not meet the Technical Regulation's requirements.
Key Amendments: Tiered Market-Placement Transition Periods
Resolution No. 737 does not change the core safety/formulation requirements of the Technical Regulation; rather, it sets different sell-off (continued market availability) deadlines for cosmetic products that "do not meet the requirements of the Technical Regulation," depending on the situation, mainly covering the following three categories:
| Situation | Market placement (sell-off) deadline |
| Cosmetic products that were NOT notified (non-notified) and were placed on the market before August 3, 2026 | May remain available on the market until August 3, 2030 |
| Notified products that contain certain substances, UV filters, or preservatives (e.g., triclocarban) | Placing into circulation only until August 3, 2026; batches already placed may remain available on the market until August 3, 2030 |
| Notified products that do not comply with the restrictions of certain entries of Annex 3 (restricted substances list) — covering Annex 3 entries 45-46, 70 (except citral), 88 (except d-limonene), 109, 114, 122, 124, 131, 133, 154, 157, 175, 196, 324, 327-359, 360 (except lavandin/intermediate lavender oil and extract), 361-365, 366 (Rosa rugosa rose flower oil), 367-371, etc. (mainly restricted/sensitizing fragrance ingredients) | May remain on the market until August 3, 2028 |
Note: Annex 3 is the restricted substances list of the Technical Regulation; the entries listed in the third category above mainly involve restricted/sensitizing fragrance ingredients such as citral, d-limonene, lavender, and rose (with exemptions for certain natural extracts). The overall trend is that cosmetic products placed on the market after August 3, 2026 must first complete electronic notification and fully comply with the Technical Regulation; for non-compliant / non-notified products already on the market, the resolution grants sell-off transitions until August 3, 2028 or August 3, 2030, depending on the situation. The resolution also contains other transitional sub-items; the complete provisions are subject to the official text of Resolution No. 737 published by Ukraine.
CIRS Reminder
This amendment provides situation-based sell-off transition periods for non-compliant / non-notified cosmetics, but products newly placed on the market after August 3, 2026 must be fully compliant. CIRS Group offers the following reminders:
- Check deadlines by situation: non-notified stock (until 2030-08-03), products containing certain substances/UV filters/preservatives (placing into circulation until 2026-08-03, sell-off until 2030-08-03), and notified products not meeting Annex 3 restrictions (until 2028-08-03) have different sell-off deadlines — companies should plan backwards by product situation;
- Complete notification promptly: cosmetics newly placed on the market after August 3, 2026 must first complete electronic notification;
- Review Annex 3 restricted substances: verify whether restricted/sensitizing fragrance ingredients such as citral, d-limonene, lavender, and rose, as well as triclocarban, comply with the Annex 3 restrictions, and adjust formulations where necessary;
- Complete pre-market compliance: ensure safety assessment, safety report, PIF, and Responsible Person / domestic agent arrangements are in place;
- Refer to the official text: the specific transitional provisions and the Annex 3 entries involved are subject to the official text of Resolution No. 737 published by Ukraine.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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