Organic Production and Labelling in Ukraine
In Ukraine, the terms “organic”, “biodynamic”, “biological”, “ecological”, “bio” and “eco” may be used for products only where the requirements of Ukrainian organic legislation are met. Certification is generally required for organic production and circulation; for imported products, the foreign certification body must also be verified and the Ukrainian importer must comply with the applicable requirements.
This article is intended for foreign producers, processors, importers, distributors and investors planning to manufacture, import or sell organic products in Ukraine.
1. Legal framework
2. Operators and certification requirements
3. Certification: certification bodies and procedure
4. Conversion period
5. Labelling requirements for organic products
6. State organic logo
7. State registers of operators and certification bodies
8. Control and supervision
9. Liability for unlawful organic labelling
10. Importing organic products into Ukraine
11. Law No. 4921-IX: alignment with EU law and future changes
12. Practical checklist
Frequently asked questions
How DLF can help
1. Legal framework
The principal current statute is the Law of Ukraine “On the Basic Principles and Requirements for Organic Production, Circulation and Labelling of Organic Products” No. 2496-VIII of 10 July 2018 (the Organic Production Law). It governs operators, certification, conversion, labelling, imports and state control.
Resolution of the Cabinet of Ministers of Ukraine “On Approval of the Procedure (Detailed Rules) for Organic Production and Circulation of Organic Products” No. 970 of 23 October 2019 sets detailed rules for eight sectors: organic crop production, organic livestock production, organic mushroom production, organic aquaculture, organic seaweed production, production of organic food, production of organic feed, and harvesting of organic wild flora.
Order of the Ministry of Agrarian Policy and Food of Ukraine “On Approval of the State Logo for Organic Products” No. 67 of 22 February 2019 established the state organic logo. Its technical description was amended by Order of the Ministry of Economic Development, Trade and Agriculture of Ukraine “On Approval of Amendments to the Technical Description of the State Logo for Organic Products” No. 1336 of 15 July 2020.
Order of the Ministry of Economic Development, Trade and Agriculture of Ukraine “On Approval of the List of Substances (Ingredients, Components) Permitted for Use in Organic Production and Permitted for Use in Limited Quantities” No. 1073 of 9 June 2020 remains in force and specifies the permitted substances and ingredients.
The Law of Ukraine “On State Regulation of Organic Production, Circulation and Labelling of Organic Products” No. 4921-IX of 30 June 2026 is partly in force. Its main provisions will apply from 21 July 2029. Until then, Law No. 2496-VIII remains the principal law in this area and will cease to have effect on 21 July 2029.
2. Operators and certification requirements
Under the Organic Production Law, an operator is a legal entity or individual entrepreneur engaged in organic production and/or circulation. For the purposes of the Law, circulation includes, among other activities, storage, transportation, import and export.
Certification is generally required for organic production and circulation. However, not every movement or storage of already labelled organic products intended for sale to final consumers constitutes circulation requiring certification. Whether a retailer, warehouse operator, carrier or catering business requires certification therefore depends on its actual activities rather than solely on its position in the supply chain.
Producers, processors, importers, exporters and other businesses carrying out organic production or circulation requiring certification must be subject to the control of a certification body. Certification is carried out separately for each organic-production sector in which the operator is active.
3. Certification: certification bodies and procedure
Certification is carried out by certification bodies accredited under Ukrainian law and entered in the state register. The process is governed by Resolution of the Cabinet of Ministers of Ukraine “On Approval of the Procedure for Certification of Organic Production and/or Circulation of Organic Products and Amendments to Cabinet of Ministers Resolution No. 970 of 23 October 2019” No. 1032 of 21 October 2020.
The operator concludes a certification agreement and submits the required description of its activities for the relevant sector. The certification body reviews production processes, facilities, traceability, records and compliance with the detailed organic rules.
An organic certificate is valid for 15 months from issue. The operator is subject to a mandatory annual inspection, and the certificate may be suspended or cancelled where the statutory grounds are met.
4. Conversion period
The conversion period is the phase during which production is brought into compliance with organic rules, but the products may not yet be marketed as organic. The minimum period depends on the production type.
| Production type | Minimum conversion period |
|---|---|
| Annual crops | At least 24 months before sowing the crop to be certified |
| Perennial crops other than forage | At least 36 months before the first organic harvest |
| Hayfields, pasture and perennial forage | At least 24 months |
| Horses and cattle for meat production | 12 months and at least three quarters of the animal’s lifetime |
| Sheep, goats, dairy livestock and pigs | 6 months |
| Poultry | 10 weeks for meat production; 6 weeks for egg production, subject to statutory conditions |
Separate rules apply to aquaculture, seaweed, beekeeping and certain production methods. The applicable conversion period should be checked for the specific type of production.
Products from the conversion period are subject to the separate designation provided by law.
5. Labelling requirements for organic products
Organic labelling of products produced in Ukraine under Ukrainian organic legislation is governed by Article 34 of the Organic Production Law.
For processed food, organic labelling is permitted if at least 95% of the ingredients of agricultural origin by weight are organic. Water and table salt are excluded from the calculation. Non-organic ingredients may be used only in the cases and within the limits permitted by law.
Ukrainian-certified organic products placed on the domestic market must display the state organic logo and the certification body’s registration code in the manner prescribed by law. Before printing or applying a label, the operator should confirm that the specific design is covered by the certification body’s written consent.
The protected expressions “organic”, “biodynamic”, “biological”, “ecological”, “bio” and “eco”, including related and derivative forms, may not be used as an organic claim without the required legal basis.
6. State organic logo
The state organic logo consists of two overlapping circles forming a stylised leaf. Its proportions, colours and typography are prescribed by Order No. 67 as amended by Order No. 1336.
The approved technical description provides for the wording “ОРГАНІЧНИЙ ПРОДУКТ” and “ORGANIC PRODUCT”. Both versions are approved for the current logo. Law No. 2496-VIII does not impose a general requirement to use only one of them.
Conditions for use:
- A valid certificate under Ukrainian organic legislation.
- Written consent from the certification body for the labelling.
- Compliance with the production and composition requirements applicable to the product.
From 21 July 2029, Law No. 4921-IX will change the labelling framework, including the language rules for the state logo. Businesses planning to use packaging over a long period should review their label designs in advance of the new rules taking effect.
7. State registers of operators and certification bodies
Official organic-sector registers are published on me.gov.ua. The State Register of Organic Operators was updated in August 2026.
The State Register of Certification Bodies identifies bodies authorised to certify under Ukrainian organic legislation.
When selecting a Ukrainian supplier, certification body or distribution partner, the current register status should be checked. A copy of a certificate is not a substitute for checking the current public record.
8. Control and supervision
The State Service of Ukraine on Food Safety and Consumer Protection exercises state control over compliance with organic production and labelling legislation. Inspections may cover the validity of certificates, the legal basis for organic labelling, traceability and compliance with the requirements governing circulation of organic products.
The State Service may take the measures prescribed by law in relation to non-compliant products and maintains the List of Foreign Certification Bodies. Certification bodies, in turn, monitor operators under certification agreements and within the powers conferred by law.
Accreditation is a separate prerequisite for a certification body to operate. Loss or suspension of accreditation affects its authority to carry out certification, so accreditation status should be checked together with the certification body’s status in the state register.
9. Liability for unlawful organic labelling
Unlawful organic labelling may lead to the withdrawal of products or restrictions on their circulation, an order to remedy the breach and financial liability under the Organic Production Law. The applicable penalty depends on the type of breach and the status of the business, and repeated breaches may have more serious consequences.
In addition, where the statutory grounds are met, the certification body may suspend or cancel the certificate, which may affect the ability to continue selling the product as organic.
Law No. 4921-IX establishes an updated system of state control and liability that will apply from 21 July 2029 together with the other main provisions of that Law.
10. Importing organic products into Ukraine
Imports are governed by Article 29 of the Organic Production Law and Order of the Ministry of Economic Development, Trade and Agriculture of Ukraine “On Approval of the Procedure for Maintaining the List of Foreign Certification Bodies” No. 985 of 26 May 2020.
A foreign organic certificate is not automatically recognised in Ukraine merely because the issuing certification body is accredited in the EU, the United States or another jurisdiction. The certification body that issued the certificate must be included in the List of Foreign Certification Bodies maintained by the State Service of Ukraine on Food Safety and Consumer Protection.
Procedure for including a foreign certification body in the List:
- A business engaged in import or export submits an application to the State Service with information on the foreign certification body, its accreditation and its supervisory authority.
- The State Service verifies the information and makes a decision within 10 working days.
- If no refusal is issued within that period, the applicant may import or export under the principle of tacit consent.
- Following a positive decision, the foreign certification body is entered in the List.
For finished organic products imported for direct sale without further processing, the importer should verify the foreign certificate and confirm that the issuing certification body is included in the List. At the same time, the official requirements for organic importers provide for certification of the Ukrainian importer where its activities involving imported organic products constitute circulation that requires certification under Ukrainian law.
11. Law No. 4921-IX: alignment with EU law and future changes
Law No. 4921-IX is intended to further align Ukrainian regulation with Regulation (EU) 2018/848 on organic production and labelling of organic products. Certain transitional and amending provisions are already in force, but the main provisions of the Law will apply from 21 July 2029.
On that date, Law No. 2496-VIII will cease to apply. The transitional provisions allow products labelled under the previous rules to continue to be produced during a three-year transition period and to remain in circulation until the end of their shelf life, subject to the statutory conditions.
For exports to the EU, a Ukrainian national organic certificate alone is not sufficient to meet EU legal requirements. The official Ukrainian requirements for organic exporters provide that an operator exporting organic products to the EU must be within the control system under Regulation (EU) 2018/848, and the products must be covered by the relevant certificate. The list of control authorities and control bodies recognised by the European Commission for third countries is established by Implementing Regulation (EU) 2021/1378, as amended, including by Commission Implementing Regulation (EU) 2026/1398.
12. Practical checklist
Producers and processors entering the Ukrainian organic market
- Identify the relevant organic-production sector and the detailed rules that apply.
- Select a certification body from the state register and conclude the certification agreement.
- Plan the conversion period for the specific crop, livestock category or production method.
- Prepare the activity description, traceability system and required records.
- Undergo the required inspection and obtain the certificate; monitor its 15-month validity period.
- Obtain the certification body’s written consent before printing or applying organic labelling.
- For processed food, verify that at least 95% of the ingredients of agricultural origin by weight are organic.
Importers of organic products into Ukraine
- Identify the foreign certification body that issued the product certificate.
- Check whether that body is included in the State Service’s List of Foreign Certification Bodies; if not, initiate the listing procedure.
- Verify that the foreign certificate is valid and covers the specific products.
- Determine whether the importer’s activities in Ukraine require Ukrainian certification based on the actual model of circulation.
- Before import, coordinate the document package and Ukrainian-market labelling with the certification body and the logistics and customs counterparties.
Frequently asked questions
Who must obtain organic certification in Ukraine?
Certification is generally required for businesses carrying out organic production or circulation within the meaning of Law No. 2496-VIII. Certain activities involving already labelled products intended for final consumers do not constitute circulation requiring certification; whether a retailer, warehouse operator or carrier requires certification therefore depends on its actual activities.
How long is the conversion period before organic certification?
Annual crops require at least 24 months before sowing; perennial crops generally require at least 36 months before the first organic harvest. Livestock, aquaculture, beekeeping and other sectors have separate conversion periods.
How can the state organic logo be used lawfully?
A valid certificate under Ukrainian legislation, compliance with the product requirements and the certification body’s written consent to the labelling are required. For processed food, the proportion of organic ingredients of agricultural origin must also be checked.
Are foreign organic certificates automatically recognised in Ukraine?
No. The issuing foreign certification body must be included in the State Service’s List of Foreign Certification Bodies, or the applicant must be entitled to rely on tacit consent after a proper application. Accreditation in the EU or another jurisdiction alone is insufficient.
Which terms may not be used without a legal basis?
The protected organic claims include “organic”, “biodynamic”, “biological”, “ecological”, “bio” and “eco”, as well as related and derivative forms in any language. Their use must be supported by the applicable certification and labelling requirements.
Where can certified operators and certification bodies be checked?
The Ukrainian state registers of operators and certification bodies are published on me.gov.ua. The separate List of Foreign Certification Bodies is maintained by the State Service of Ukraine on Food Safety and Consumer Protection.
When do the main provisions of the 2026 Organic Law take effect?
The main provisions take effect on 21 July 2029. Until then, Law No. 2496-VIII remains the principal law in this area, although certain transitional and amending provisions of Law No. 4921-IX are already in force.
How DLF can help
DLF attorneys-at-law supports foreign producers, processors, importers and investors at every stage of entering the Ukrainian organic-products market: from determining operator status and structuring the supply model to certification, recognition of foreign certification bodies, label and advertising review, supplier contracts and preparation for the 2029 regulatory transition. Relevant DLF practice areas include Agribusiness and Advertising Law.
Iurii Dynys, Counsel, Attorney-at-law — DLF attorneys-at-law.
Contact: +380 44 384 24 54, info@dlf.ua.
This material is intended for general information. The application of the approaches described depends on the circumstances of the specific situation and requires a separate legal assessment.