Cosmetic Product Notification in Ukraine in 2026: Requirements, Documents and Penalties

The author of the article: Denis Korablyov

Modified date: 20 July 2026

If your business has even the slightest connection to cosmetics, you need to understand cosmetic product notification. The new requirements apply to the entire cosmetics supply chain – manufacturers, importers, brand owners, distributors, stores, salons, and hotels. However, their responsibilities are different: the Responsible Person submits the notification, while sellers must inspect the product and retain documents confirming its origin.

The main thing to understand from the outset is that notification is not an authorisation, but a notice to the state about a product you are placing on the market. The system has been simplified compared with the previous authorisation procedure, but “simplified” does not mean “nothing needs to be done”: businesses that fail to prepare the documents correctly are exposed to risks.

In this article, we explain in simple terms what cosmetic product notification is, what qualifies as a cosmetic product, who must submit the notification, which documents each party needs, what information must be provided during notification, what to do with remaining stock, and what penalties may apply for violations.

What is cosmetic product notification?

Previously, to sell certain types of cosmetics legally, businesses had to go through an authorisation procedure: collect documents, obtain official conclusions, and wait. The approach has now changed. The state has introduced notification – a notice concerning a cosmetic product that you intend to place on the market. It is not an authorisation that must be “secured”, but a way of informing the state before sales begin.

Product information is entered into the Electronic Cosmetic Product Notification System, which is administered by the Ministry of Health. The notification procedure was approved by Ministry of Health Order No. 2147 dated 18 December 2023, and the electronic system became operational on 1 December 2025.

The requirements themselves are established by the Technical Regulation on Cosmetic Products, approved by Cabinet of Ministers Resolution No. 65 dated 20 January 2021. It was developed on the basis of European Regulation (EC) No. 1223/2009, meaning that Ukraine has adopted EU rules. The Technical Regulation entered into force on 3 August 2024, with a two-year transition period provided for businesses.

What qualifies as a cosmetic product?

This is where many business owners make their first mistake. They think: “Cosmetics do not concern me because I do not sell make-up.” However, cosmetic products are a much broader category than they may appear.

Cosmetic products include all substances and mixtures intended to be applied to the external parts of the body (skin, hair, nails, and lips), as well as to the teeth and the mucous membranes of the oral cavity, for the purpose of cleaning, perfuming, changing their appearance, protecting them, or keeping them in good condition. 

These include, in particular:

• perfumes, eau de toilette, and eau de parfum;
• shower gels, bath foams, and shampoos;
• deodorants and antiperspirants;
• toothpastes and oral hygiene products;
• creams, lotions, masks, and tanning products;
• shaving and aftershave products;
• colour cosmetics, nail polish, and nail polish removers.

Those potentially affected include brick-and-mortar and online cosmetics stores, sellers of refill perfumes, certain grocery stores, dental clinics, beauty salons that sell products to clients, and even hotels that provide their own cosmetic products in guest rooms. Even if cosmetics are not your main product category, the requirement applies to you if you sell them.

Who must notify cosmetic products?

The key rule is that the product must be notified by the party that first places it on the market in Ukraine. 

Under the Technical Regulation, this party is referred to as the Responsible Person – a resident manufacturer, an importer, or a person appointed by them in writing. 

Importantly, a distributor does not automatically become the Responsible Person simply because it was the first to sell the product – this depends on its role, the product labelling, and the name under which the product is placed on the market.

To determine who is responsible for notification in your situation, refer to the table below:

The information is entered into the Electronic Notification System by the managers or authorised employees of the Responsible Person.

Documents required for cosmetics sellers, manufacturers, and importers

What you need to do depends on your role. Your responsibilities vary depending on whether you are a manufacturer, importer, Responsible Person, or merely resell products that have already been placed on the market. For some businesses, the main tasks are submitting the notification and preparing the Product Information File, while others must verify the product documents, ensure traceability, and check that the product is labelled correctly.

1. What sellers of already notified cosmetics need to do

Many cosmetics retailers operate as Group 2 sole proprietors. If you resell cosmetics supplied by an authorised supplier, you generally do not need to notify the product again. However, you should obtain confirmation that the product has been notified, retain contracts and invoices for each batch, check the Ukrainian-language labelling, the Responsible Person’s details, the expiry date, and compliance with storage conditions. The documents must make it possible to trace when and from whom you received the products.

If you sell cosmetics at retail, do not forget about the requirement to use an RRO cash register or software RRO when accepting payments from customers – this is a separate obligation, and violations are also subject to penalties.

2. Notification requirements for manufacturers, importers, and private-label brands

If you manufacture, import, or commission cosmetics under your own brand, you are the Responsible Person and must submit the notification. To do so, you need a Product Information File containing:

• a description of the cosmetic product that enables its clear identification;
• a Cosmetic Product Safety Report;
• a description of the manufacturing method and evidence of compliance with Good Manufacturing Practice (GMP);
• evidence supporting the claimed effect of the product, where justified by the labelling;
• information on animal testing, where applicable.

The Product Information File must be retained for 10 years after the date on which the last batch of the cosmetic product was placed on the market. The Cosmetic Product Safety Report must be prepared by a qualified safety assessor, often with the involvement of specialised laboratories.

A separate case is refill perfume. If a seller transfers perfume into different containers, changes the labelling, or sells it under their own brand, they may assume the responsibilities of a manufacturer or Responsible Person. This business model must be assessed separately, as the notification of the original product may not be sufficient.

What information must be submitted during notification?

The Responsible Person submits the notification through the Ministry of Health’s Electronic Notification System. The minimum set of product information includes:

• the product category and name;
• the name and address of the Responsible Person where the Product Information File is kept;
• the country of origin – for imported products;
• the presence of nanomaterials;
• the presence of CMR substances – carcinogenic, mutagenic, or toxic for reproduction substances classified as categories 1A or 1B;
• a frame formulation – for the purposes of prompt and appropriate medical treatment;
• the original labelling and, where necessary, a photograph of the packaging.

Please note that a frame formulation may be selected during notification if the product’s composition fully corresponds to it. If none of the proposed frame formulations is suitable, a custom formulation must be entered into the system, specifying the INCI name and the concentration or concentration range of each ingredient.

What happens to remaining cosmetic stock after 3 August 2026?

Separate transitional rules apply to cosmetic products legally placed on the market before 3 August 2026. Initially, Resolution No. 65 established only a general rule: making such products available on the market could not be prohibited or restricted due to non-compliance with the new requirements, but it did not specify a final deadline. In June 2026, the Cabinet of Ministers adopted Resolution No. 737, which clarified this right: 

cosmetic products that were not notified but were placed on the market before 3 August 2026 may continue to be made available on the market and sold until 3 August 2030.

An important point regarding the transitional period: Resolution No. 737 enters into force six months after its publication – approximately in December 2026. Therefore, immediately after 3 August 2026, the sale of legally held stock is based on the existing provision of Resolution No. 65 (“may not be prohibited or restricted”), while the final deadline of 3 August 2030 is established by Resolution No. 737 once it enters into force. At the same time, the notification deadline of 3 August 2026 is not postponed: after that date, new products may not be placed on the market without notification – this applies only to the sale of stock placed on the market earlier.

To confirm that a specific batch was placed on the market before 3 August 2026, retain primary documents that make it possible to trace its origin and delivery date: contracts, delivery notes, customs declarations for imported products, and other clearly dated documents. An inventory report may strengthen the evidence supporting the remaining stock, but the law does not establish it as a mandatory or exclusive document – it is primarily a practical recommendation.

Penalties for selling cosmetic products without notification

Compliance with the requirements is monitored by the State Service of Ukraine on Medicines and Drugs Control as part of state market surveillance. Liability is established by Article 44 of Law No. 2735-VI. The amount of the penalty depends on who committed the violation – the person who placed the product on the market or the distributor – whether the product merely failed to comply with the requirements or presented a serious risk, and whether the violation was repeated. The amounts are calculated using the tax-free minimum income of UAH 17.

The specific legal classification depends on your role and the circumstances. If a reseller cannot provide documents confirming who placed the product on the market, the reseller may face the same penalties as the person who placed the product on the market, as this approach has appeared in court practice.

In addition to imposing a penalty, the market surveillance authority may restrict or prohibit the product from being made available on the market or require its withdrawal or recall, depending on the violation and the level of risk. As a result, the total losses may significantly exceed the amount of the penalty itself.

Moreover, inspections are not limited to scheduled checks: a complaint from a competitor or dissatisfied customer may be sufficient. It is therefore better to organise your documents in advance and prepare for an inspection by the market surveillance authority.