On October 5, 2026, Ukraine notified the World Trade Organization (WTO) of a draft amending Ukraine Cabinet of Ministers Resolution No. 65 (Cosmetic Products Technical Regulation) (G/TBT/N/UKR/414).
The draft proposes to extend, from August 3, 2026 to July 31, 2027, the deadline for placing on the Ukrainian market cosmetic products that have not been notified in accordance with the Technical Regulation on Cosmetic Products and that do not comply with that Regulation. The draft is intended to enter into force on December 14, 2026, and the deadline for comments is November 4, 2026.
Amendments and Entry into Force
Pursuant to the draft annexed to this notification, point 3 of Ukraine Cabinet of Ministers Resolution No. 65 of January 20, 2021 (Cosmetic Products Technical Regulation, hereinafter “Resolution No. 65”) is amended, substituting the date “August 3, 2026” contained therein with “July 31, 2027”.
Note: Ukraine expressly stated in the notification that this amendment does not introduce any new technical requirements for cosmetic products and does not otherwise modify the Technical Regulation on Cosmetic Products itself; it only adjusts the dates of the transition period.
Eliminating the Inconsistency in the Transition Period Created by Two Resolutions
Ukraine states this amendment seeks to resolve conflicting transition-period rules for cosmetics from two co-existing Cabinet of Ministers resolutions:
- Resolution No. 976 of July 29, 2026: amending Resolution No. 65 (published and entered into force on August 1, 2026). It extends the transition market placement deadline to July 31, 2027 and amends Article 25: cosmetic safety assessments must be conducted by experts holding a master’s degree in “I2 Medicine”, “I8 Pharmacy” or relevant fields approved by Ukraine’s Ministry of Health. This qualification clause takes effect six months after publication, namely February 1, 2027.
- Resolution No. 737 of June 4, 2026: another amendment to Resolution No. 65, introducing a separate transition-period provision effective in mid-December 2026.
As the two resolutions contain different wording for the transition clause, this draft uniformly revises the date to July 31, 2027, with entry into force scheduled for December 14, 2026.
Current Arrangements for the Transition Period
The current arrangements for the transition period for cosmetic products in Ukraine are as follows:
- Deadline for placing on the market: July 31, 2027
Cosmetic products placed on the Ukrainian market before that date may not be prohibited or restricted from being made available on the market merely because they do not comply with the requirements of Resolution No. 65.
For imported products, placing on the market is generally determined by the date of importation; for products of Ukrainian origin, by the date of manufacture.
- Deadline for continued availability on the market: August 3, 2030, a date left unchanged by this amendment.
In other words, products placed on the market during the transition period that do not comply with the requirements of Resolution No. 65 may remain on sale until that date at the latest.
Impact on Cosmetics Companies and Recommendations
- This amendment only extends the transition period and introduces no new technical requirements: Companies already exporting cosmetic products to Ukraine will obtain approximately one additional year of grace.
- Note the meaning of the deadline: July 31, 2027 is the deadline for placing on the market, not the deadline for sales. Products already imported into warehouses in Ukraine may continue to be sold until August 3, 2030; however, products newly imported after August 1, 2027 must fully comply with the technical regulations.
- Pay attention in parallel to the qualification requirements for safety assessors: Article 25 of Resolution No. 65, as amended by Resolution No. 976, will enter into force on February 1, 2027, requiring that the safety assessment be performed by an expert holding a master’s degree in a relevant field. As this date falls earlier than the end of the transition period, companies should verify in advance whether the qualifications of their safety assessment signatories meet the new requirements.
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