New Technical Regulation on Machinery in Ukraine

Ukraine’s new Technical Regulation on Machinery was developed on the basis of Regulation (EU) 2023/1230 and will replace the Technical Regulation on Machine Safety that has applied since 2013. Before the new regulation takes effect, businesses should distinguish products already placed on the Ukrainian market from those that have merely been manufactured or imported, remain in storage or are still in transit.

Until 19 January 2027, machinery in Ukraine is governed by the Technical Regulation on Machine Safety, approved by Cabinet of Ministers of Ukraine Resolution No. 62 of 30 January 2013. From 20 January 2027, the Technical Regulation on Machinery, approved by Cabinet of Ministers of Ukraine Resolution No. 1630 of 10 December 2025, will apply. The key transitional event is placing a product on the market, meaning its first making available on the Ukrainian market. Manufacturers and importers should already identify the applicable conformity assessment procedure, review existing certificates and prepare their technical documentation for the new requirements.

This article is intended for foreign and Ukrainian manufacturers of products within the scope of the Technical Regulation on Machinery, as well as importers, distributors, compliance teams and legal counsel planning supplies to the Ukrainian market.

1. Current regulatory framework for machinery in Ukraine

2. Changes from 20 January 2027

3. Scope of the new Technical Regulation on Machinery

4. Conformity assessment under the new Technical Regulation on Machinery

5. Manufacturer obligations

6. Obligations of importers and distributors

7. Technical documentation, instructions and language requirements

8. Transitional rules for products and certificates

9. CE marking and ACAA in Ukraine

10. Wartime simplification before 20 January 2027

11. Market surveillance and consequences of non-compliance

12. Compliance checklist before 20 January 2027

Frequently asked questions

How DLF can help

1. Current regulatory framework for machinery in Ukraine

Technical regulation of machinery in Ukraine operates at two levels. The Law of Ukraine “On Technical Regulations and Conformity Assessment” No. 124-VIII sets the general framework for developing, adopting and applying technical regulations and conformity assessment procedures, as well as the rules on designating conformity assessment bodies, declarations of conformity and use of the conformity mark to technical regulations.

At product level, the Technical Regulation on Machine Safety applies until 19 January 2027. Its scope covers machinery, interchangeable equipment, safety devices, lifting accessories, chains, ropes and webbing, removable mechanical transmission devices and partly completed machinery.

For machinery outside the list in the Annex to the current regulation, internal production control is used. For machinery on that list, the procedure depends, among other things, on whether the applicable national standards covering all relevant essential requirements have been fully applied: internal production control is available in certain cases, while others require a designated conformity assessment body.

Market surveillance is governed by the Law of Ukraine “On State Market Surveillance and Control of Non-Food Products” No. 2735-VI. The State Labour Service of Ukraine (Derzhpratsi) is the principal market surveillance authority in this area, subject to specific exceptions for certain product groups.

2. Changes from 20 January 2027

The new Technical Regulation on Machinery changes the conformity-assessment framework for certain machinery and related products and gives more detailed rules for economic operators in the supply chain.

3. Scope of the new Technical Regulation on Machinery

The principal product categories under the new regulation broadly correspond to the scope of the current regulation: machinery, interchangeable equipment, safety components, lifting accessories, chains, ropes and webbing for lifting purposes, removable mechanical transmission devices, and partly completed machinery.

The exclusions should be checked against the new regulation itself. They include, among other things, certain safety components supplied by the manufacturer as spare parts to replace identical components; specific fairground and amusement equipment; certain products for nuclear installations; weapons; particular vehicles, tractors, vessels and offshore units; equipment specially designed for military or police purposes; certain laboratory equipment; and electrical products governed by other technical regulations.

For conformity assessment purposes, the new regulation distinguishes products listed in Part A and Part B of Annex 1. The classification of particular machinery or a related product should therefore be checked directly against Annex 1 rather than inferred solely from its commercial name or sector of use.

4. Conformity assessment under the new Technical Regulation on Machinery

From 20 January 2027, the applicable conformity assessment procedure will depend on whether the relevant category of machinery or related product is listed in Part A or Part B of Annex 1.

Products listed in Part A. A designated conformity assessment body must be involved. The manufacturer and any natural or legal person making a substantial modification to machinery or a related product must use one of the following procedures: type examination (Module B) followed by conformity to type based on internal production control (Module C), conformity based on full quality assurance (Module H), or conformity based on unit verification (Module G). Module A is not available for this group.

Products listed in Part B. Internal production control (Module A) may be used if the machinery or related product is designed and manufactured in accordance with the applicable national standards from the relevant list or common specifications that cover all applicable essential health and safety requirements. Otherwise, one of the procedures involving a designated body must be used: B+C, H or G.

Machinery and related products not listed in Annex 1. Internal production control (Module A) applies.

The general conformity assessment modules are set out in the Technical Regulation on Conformity Assessment Modules, approved by Cabinet of Ministers of Ukraine Resolution No. 95 of 13 January 2016.

As of 21 September 2026, a dedicated list of national standards for the new Technical Regulation on Machinery has not been published on the official lists of national standards under technical regulations published by the Ministry of Economy and Environment of Ukraine; the machinery materials available there concern the current Technical Regulation on Machine Safety. This is particularly relevant for products listed in Part B because use of Module A depends on satisfying the conditions of the new regulation.

Where a designated conformity assessment body must be involved, its current scope of designation should be verified in the official register before it is engaged. A designation under the current Technical Regulation on Machine Safety does not automatically mean that the body will be authorised to perform conformity assessment under the new regulation; its scope of designation should be checked separately after 20 January 2027.

5. Manufacturer obligations

The manufacturer must complete the applicable conformity assessment procedure and draw up the technical documentation before placing machinery or related products on the market or, where the regulation so requires, putting them into service. Technical documentation and the declaration of conformity must generally be retained for at least 10 years after the product is placed on the market or put into service.

The technical documentation must allow the product’s conformity with the regulation to be assessed. Depending on the product, it includes a description of the machinery or related product, the risk assessment, drawings and diagrams, information on the essential requirements applied, standards or other technical specifications used, and evidence supporting the technical solutions adopted.

The declaration of conformity is drawn up by the manufacturer or, where applicable, its authorised representative. It must be in Ukrainian or be translated into Ukrainian. The conformity mark to technical regulations is affixed in accordance with the Cabinet of Ministers of Ukraine Resolution No. 1184 of 30 December 2015 “On Approval of the Form and Description of the Conformity Mark to Technical Regulations, and the Rules and Conditions for Its Affixing”.

The manufacturer must also ensure product identification, provide its name and contact details, and supply the required instructions and safety information. If non-conformity or a risk is identified after the product has been placed on the market, the manufacturer must take corrective action and, where required, notify the market surveillance authority.

6. Obligations of importers and distributors

Importers

Importers must place on the market only machinery and related products that comply with the Technical Regulation. Before placing machinery or related products on the market, the importer must verify that the manufacturer has completed the applicable conformity assessment procedure, prepared the technical documentation, affixed the conformity mark, drawn up the declaration of conformity and provided the required instructions in Ukrainian. The importer must also provide its own name and contact details in the manner required by the regulation.

If there are grounds to believe that a product does not comply with the requirements, the importer must not place it on the market until the non-compliance is remedied. The importer must retain a copy of the declaration of conformity for at least 10 years after the product is placed on the market and ensure that the market surveillance authorities can obtain access to the technical documentation on request.

Distributors

Before making machinery or related products available on the market, the distributor must check that the required conformity mark is affixed, that the product is accompanied by the declaration of conformity and that the required instructions and safety information are provided in Ukrainian.

If there are grounds to believe that the product is non-compliant, it must not be made available on the market until the non-compliance is remedied. Economic operators must also retain the information needed to identify suppliers and recipients in the supply chain for the period required by the regulation.

7. Technical documentation, instructions and language requirements

Operating instructions and safety information for machinery and related products placed on the Ukrainian market must be provided in Ukrainian. Operating instructions may be provided electronically if the means of access is indicated on the machinery, related product, packaging or an accompanying document; the format allows the instructions to be printed, downloaded and stored for offline use; online access is maintained for the expected service life of the product and for at least 10 years after it is placed on the market; and, if requested by the user at the time of purchase, a paper copy is provided free of charge within one month. If the product is intended for non-professional users, or may reasonably be expected to be used by them, the safety information essential for safe putting into service and use must also be provided on paper.

For partly completed machinery, a declaration of incorporation is required instead of a declaration of conformity. Its content is set out in Part B of Annex 5 to the new regulation and includes identification details, information about the manufacturer, the essential requirements fulfilled and the undertaking to provide the relevant technical information.

Safety information and markings must also comply with the language requirements of the regulation. Businesses should therefore treat Ukrainian-language documentation as part of the compliance file rather than as a post-import formality.

8. Transitional rules for products and certificates

The making available on the market of products that comply with the Technical Regulation on Machine Safety and were placed on the market before 20 January 2027 may not be prohibited or restricted solely because those products do not comply with the new Technical Regulation on Machinery.

“Placing on the market” means the first making available of a product on the Ukrainian market. Manufacture, importation into Ukraine or storage alone does not amount to placing the product on the market. Accordingly, a product that is still in stock or in transit on 20 January 2027 and has not yet been first made available on the Ukrainian market must comply with the new regulation.

Type-examination certificates and quality-system approval decisions issued under the current regulation remain valid until their expiry dates. After expiry, any further conformity assessment must be carried out under the new regulation.

The new regulation contains no separate transitional rule specifically for products lawfully placed on the market under the wartime simplification regime. For products relying on that regime, businesses should therefore verify the documentation for the specific batch and the legal basis on which the product was placed on the market before any further supply after 20 January 2027.

9. CE marking and ACAA in Ukraine

CE marking alone does not replace Ukrainian conformity assessment requirements or the Ukrainian conformity mark to technical regulations.

Regulation (EU) 2023/1230 is an EU law act and does not apply directly in Ukraine. The Ukrainian Technical Regulation on Machinery brings Ukrainian regulation closer to EU law, but until mutual recognition is introduced, manufacturers and importers must comply with the Ukrainian procedures prescribed for the particular product.

The Agreement on Conformity Assessment and Acceptance of Industrial Products (ACAA) between Ukraine and the EU has not yet entered into force. The machinery sector remains one of the priority sectors, together with low-voltage electrical equipment and electromagnetic compatibility. Businesses should therefore not assume automatic mutual recognition of certificates for supplies to Ukraine in 2026–2027.

10. Wartime simplification before 20 January 2027

The current Technical Regulation on Machine Safety provides a special wartime simplification. Until martial law is terminated or cancelled and for 90 calendar days thereafter, products included in the list approved by Cabinet of Ministers of Ukraine Resolution No. 1213 of 17 November 2023 “On Approval of the List of Products for the Purposes of Applying Certain Technical Regulations and on Amendments to Certain Resolutions of the Cabinet of Ministers of Ukraine”, and falling within the scope of the current Technical Regulation on Machine Safety, may be made available on the market and/or put into service without a declaration of conformity or a declaration of incorporation for partly completed machinery and without the conformity mark to technical regulations.

A company relying on this simplification must therefore check whether the Technical Regulation on Machine Safety applies to the specific product and whether that product is included in the special list. There is no general exemption from these requirements for all products within the scope of the regulation.

From 20 January 2027, the new Technical Regulation on Machinery will apply and contains no equivalent exception for the period of martial law. Businesses currently relying on the special simplification should prepare the full compliance documentation under the new regulation in advance.

11. Market surveillance and consequences of non-compliance

Market surveillance in this area is based on the Law of Ukraine “On State Market Surveillance and Control of Non-Food Products”. The Cabinet of Ministers of Ukraine Resolution No. 1069 of 28 December 2016 “On Approval of the List of Product Types Subject to State Market Surveillance by State Market Surveillance Authorities”, as amended with effect from the entry into force of the new regulation, assigns market-surveillance responsibility for machinery, related products and partly completed machinery to Derzhpratsi, subject to specific exceptions. Fire-fighting and emergency-rescue machinery, for example, falls within the competence of the State Emergency Service of Ukraine.

The market surveillance authority may carry out inspections, request documents, take product samples for testing and impose restrictive measures. Depending on the breach, it may restrict or prohibit a product from being made available on the market, withdraw the product from the market or recall it.

If a restrictive measure or sanction is imposed, the legal basis of the decision, the status of the economic operator and the factual circumstances of the supply should be reviewed separately.

12. Compliance checklist before 20 January 2027

• Product classification. Determine whether the relevant category of machinery or related product is listed in Part A or Part B of Annex 1, or is not listed in Annex 1.
• Transitional status. Separate products already placed on the market before 20 January 2027 from products that have only been manufactured, imported, stored or remain in transit.
• Existing certificates. Check expiry dates for type-examination certificates and quality-system approval decisions.
• Designated body. Where involvement of a designated body is required, verify its current scope of designation under the new regulation rather than relying solely on its status under the current regulation.
• Technical documentation. Compare the existing technical documentation with the requirements of the new regulation, including the risk assessment, drawings, software-related information and applicable essential requirements.
• Operating instructions. Prepare Ukrainian-language instructions and, if electronic format will be used, satisfy the requirements for access, retention and a paper copy.
• Declaration. Prepare the declaration of conformity or, for partly completed machinery, the declaration of incorporation in the format required by the new regulation.
• Conformity marking. Check the Ukrainian conformity mark to technical regulations and other mandatory identification information.
• National standards. Monitor publication of the standards list for the new regulation, especially for products listed in Part B of Annex 1.
• Supply-chain responsibilities. Agree with the importer and distributor who is responsible for documentation, marking, traceability and corrective action.
• Substantial modification. Before hardware or software changes are made, assess whether the modification may be substantial and may place manufacturer obligations on the person making it.
• Wartime simplification. Where a supply is made without a declaration and conformity mark, confirm that the specific product is included in the list under Resolution No. 1213 and prepare for the end of that regime when the new regulation takes effect.

Frequently asked questions

When does the new Technical Regulation on Machinery take effect in Ukraine?

The new Technical Regulation on Machinery takes effect on 20 January 2027. The Technical Regulation on Machine Safety continues to apply through 19 January 2027.

Can machinery covered by the previous rules still be sold after 20 January 2027?

Yes, if the product was placed on the Ukrainian market before 20 January 2027 and complied with the current Technical Regulation on Machine Safety. A product that is only in stock or in transit on that date and has not yet been first made available on the Ukrainian market must comply with the new regulation.

Is CE marking sufficient for machinery and related products to be made available on the Ukrainian market?

No. CE marking does not replace Ukrainian conformity assessment or the conformity mark to technical regulations. This may change if and when the ACAA enters into force, but the agreement is not currently in force.

Is a designated conformity assessment body always required?

No. A designated body is mandatory for products listed in Part A of Annex 1. For products in Part B, the possibility of using Module A depends on compliance with the requirements concerning standards or common specifications. Module A applies to products outside Annex 1.

Must operating instructions be in Ukrainian?

Yes. The new regulation also permits electronic instructions subject to requirements concerning access, printing and downloading, the online availability period and a free paper copy on request.

What happens to existing type-examination certificates?

Type-examination certificates issued under the current regulation remain valid until they expire. After expiry, the applicable conformity assessment is carried out under the new regulation.

Is the wartime simplification under the Technical Regulation on Machine Safety currently available?

Yes, but only for products included in the special list approved by Cabinet of Ministers of Ukraine Resolution No. 1213 to which the current Technical Regulation on Machine Safety applies. It is not a general exemption for all products within the scope of the regulation.

What should a foreign manufacturer do before 20 January 2027?

The first steps are to determine the legal classification of the product under Annex 1, check the validity of existing certificates and the scope of designation of the relevant conformity assessment body, update the technical documentation and Ukrainian-language instructions, and agree with the importer on responsibility for the declaration, marking and traceability.

How DLF can help

DLF attorneys-at-law supports foreign machinery manufacturers, importers and distributors at all stages of entering the Ukrainian market: from selecting a market-entry structure and documenting relationships with an importer or distributor to reviewing supply contracts, allocating responsibility for conformity assessment and marking, legally reviewing technical documentation and declarations, coordinating with designated conformity assessment bodies, preparing for market surveillance, and addressing customs and product-liability risks. For such projects, DLF’s Contract Law and Corporate Law / M&A practices may be particularly relevant.

Author: Igor Dykunskyy, LL.M., Partner, Attorney-at-law, DLF attorneys-at-law

Contacts: +380 44 384 24 54, info@dlf.ua

This material is intended for general information purposes. The application of the approaches described depends on the circumstances of the specific situation and requires a separate legal assessment.