In 2026, Ukraine launched a systematic overhaul of state control. The adoption of Law of Ukraine No. 4839-IX of 8 April 2026 significantly changes the rules governing the inspection of goods placed on the market, imported or sold via distance selling channels. The main aim of the reform is to align national legislation with the European model based on EU Regulation 2019/1020.
For importers, manufacturers and distributors, these changes mark a shift from the formal collection of certificates to ensuring genuine compliance and traceability across supply chains. This analytical overview from Alden’s experts will help businesses understand the new regulatory requirements and prepare for the end of the transition period.
The legislator has provided for the provisions of Law No. 4839-IX to come into force in stages, allowing businesses to adapt their operational processes in good time.
| Date | Implementation phase and regulatory changes |
|---|---|
| 03.05.2026 | Official entry into force of the Act in its general (framework) part. |
| 02.05.2027 | Critical deadline. The launch of risk-based customs controls, online surveillance and new powers for inspectors. |
| 02.05.2029 | Entry into force of the provisions concerning the liability of fulfilment service providers. |
| Following the signing of the ACAA Agreement | Implementation of provisions on direct cooperation and data exchange with the European Union’s market surveillance authorities. |
A mandatory horizontal requirement is being introduced: for certain product categories may only be placed on the market if there is a Ukrainian resident acting as the responsible entity.
A specific list of technical regulations to which this requirement will apply is due to be approved shortly by the Cabinet of Ministers of Ukraine. The majority of industrial goods are likely to fall within the scope of this provision: electrical equipment, machinery, radio equipment, personal protective equipment (PPE), toys and construction products.
The responsible entity may be a resident manufacturer, an importer or an authorised representative. Their key responsibilities include keeping declarations and technical documentation, providing them upon request by inspectors, and cooperating to rectify non-conformities. The name and contact details of this entity must be indicated on the product, its packaging or the accompanying documents.
The law formally enshrines the concept of online supervision. Products are deemed to be made available on the Ukrainian market if the distance selling offer is directed at Ukrainian consumers. Indicators of such targeting include the use of the Ukrainian language, the display of prices in hryvnia, or the availability of a delivery option to Ukraine.
Market surveillance authorities have been granted the right to inspect online product listings and carry out unannounced test purchases online. Particular emphasis has been placed on ‘information society service providers’ (marketplaces). Platforms face financial penalties for failing to comply with orders to restrict access to pages featuring non-compliant products.
When non-food products are imported, the customs authorities will carry out checks based on clear checklists drawn up by the market surveillance authorities. The checks will cover conformity marks, labelling, the presence of declarations of conformity (or declarations of performance for construction products) and the details of the responsible resident.
Should any discrepancies be identified, customs authorities are entitled to suspend the clearance of the consignment. The standard suspension period is up to 4 working days. During the period of martial law, this period may be extended by a further 4 working days (up to a total of 8 working days), which requires importers to prepare a complete set of documents before the consignment crosses the border.
Regulatory authorities are being provided with tools to verify the authenticity of products throughout the supply chain. Inspectors are authorised to request documentation regarding the volumes of deliveries and stock levels in warehouses.
A new procedural tool is the reverse engineering procedure. It involves a detailed examination of a sample (analysis of its design, software and components) to compare its actual characteristics with the requirements set out in the regulations. All stages of the inspection and the evidence gathered will be documented through photographs and video recordings.
The Act expands the list of documentation that may be subject to inspection (technical specifications, instructions, general descriptions). It is important to note that documents relating to quality management systems are required only in cases where this is expressly provided for in the conformity assessment procedure for a specific technical regulation.
The key rule of the new compliance framework is complete data synchronisation. The information in the online product listing, the physical labelling on the packaging, the details in the customs documents and the data in the manufacturer’s technical file must all match exactly. Any discrepancies will be regarded as an indicator of regulatory risk.
Companies providing services relating to the storage, packaging and dispatch of goods (without acquiring ownership) will become fully-fledged market surveillance entities from May 2029. If a foreign manufacturer has no other registered representative in Ukraine, the responsibilities for storing technical documentation and liaising with inspectors fall to the fulfilment centre.
To avoid the risks of goods being held up at customs, restrictions on online content or the imposition of fines, importers and manufacturers would be well advised to carry out an internal audit in accordance with the following procedure:
| Control Area | Necessary steps and measures |
|---|---|
| Regulatory audit | Review the product range. Identify the applicable technical regulations and check whether the products are subject to the requirement to have a responsible resident. |
| Compliance documentation | Compile sets of declarations and protocols. Agree with the foreign manufacturer on the procedure for the urgent provision of the technical file upon request by the supervisory authority. |
| Labelling audit | Check the presence of a conformity mark, instructions in Ukrainian language and contact details of the responsible entity on the packaging or in the documentation. |
| Audit of online resources | Ensure that the information on product pages (online shops, marketplaces) is fully consistent with the physical labelling of the products. |
Deliberately delaying preparations or ignoring requests will have serious consequences:
The preparation of technical documentation and the adaptation of processes to meet the requirements of Law No. 4839-IX require specific legal and engineering expertise. The Alden team provides comprehensive business support during the adaptation phase:
Ensure the stability of your business’s operational processes in advance. Contact the experts at Alden to arrange a professional compliance audit.
