Ukraine Notifies WTO on Proposed Changes to Cosmetic Regulation for EU Harmonization

Date
31 Jul 2025

GPC - Global Product Compliance

On 30 July 2025, Ukraine officially notified the World Trade Organization (WTO) of a draft resolution proposing amendments to its Technical Regulation on Cosmetic Products, originally adopted under Cabinet Resolution No. 65 of 20 January 2021. The proposal, submitted by the Ministry of Health of Ukraine, aims to harmonize national cosmetic legislation with Regulation (EC) No 1223/2009 of the European Union — a key step in strengthening product safety, enhancing consumer protection, and reducing trade barriers for cosmetic products. Key Highlights of the Draft Resolution The draft resolution introduces significant amendments to clauses 38, 39, 47, and 52 of the current Technical Regulation. It also presents updated versions of Annexes 2–6, which include lists of restricted, prohibited, and permitted substances in cosmetic formulations. 1. Alignment with EU Cosmetic Regulation (EC) No 1223/2009 The proposed changes are aimed at ensuring full compliance with updated EU standards, especially those concerning carcinogenic, mutagenic, or reprotoxic (CMR) substances. This alignment is critical for maintaining market access for Ukrainian-made cosmetics in the EU and globally. 2. Ingredient Labelling with INCI Names To simplify labelling and reflect international practices, the amendments allow the use of INCI (International Nomenclature of Cosmetic Ingredients) names without requiring additional translations into Ukrainian. This streamlines product packaging and enhances cross-border trade efficiency. 3. Revised Labelling Requirements for Packaging The draft introduces more specific rules for labelling on primary and secondary packaging: • If only primary packaging is used, all mandatory labelling elements must be included on it. • If secondary packaging is present, the required labelling should appear on the outer (secondary) packaging, while the primary packaging does not need to display the list of ingredients. 4. Transitional Provisions Provisions have been included for substances listed in Annexes 2, 3, 4, 5, and 6, allowing for a transition period to help manufacturers and importers adjust to the updated requirements. Objectives and Impact The main objectives of the proposed amendments are: • Enhancing consumer information and labelling clarity. • Promoting regulatory harmonization with the EU. • Facilitating international trade by reducing technical barriers. By updating its national regulation, Ukraine demonstrates its commitment to aligning with European standards, which is essential for improving market access and protecting consumer health and safety. Legal and Regulatory References • The Law of Ukraine “On Technical Regulations and Conformity Assessment” • Cabinet Resolution No. 65 “On Approval of the Technical Regulation on Cosmetic Products” dated 20 January 2021 Implementation Timeline and Comment Period The adoption and enforcement dates of the Resolution are yet to be determined. Stakeholders have a 60-day window from the notification date to review and provide feedback on the draft to the Ministry of Economy of Ukraine.


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