News Details

On 24 February 2026, Ukraine officially notified the World Trade Organization (WTO) of the adoption of Ministry of Health Order No. 55, dated 15 January 2026 and titled “On Approval of the Requirements Restricting the Use of Certain Epoxy Derivatives in Materials and Articles Intended to Come into Contact with Food.”

This Order introduces mandatory restrictions on specific epoxy derivatives used in food contact materials (FCMs), thereby aligning Ukrainian regulations with EU chemical safety standards as set out in Commission Regulation (EC) No. 1895/2005.

Materials and Substances Covered

The requirements apply to materials and articles intended to come into contact with food, including active and intelligent FCMs, if they contain any of the following substances:

• BADGE – 2,2-bis(4-hydroxyphenyl)propane bis(2,3-epoxypropyl) ether, CAS No. 1675-54-3, including certain derivatives.
• BFDGE – bis(hydroxyphenyl)methane bis(2,3-epoxypropyl) ethers, CAS No. 39817-09-9.
• NOGE – other novolac glycidyl ethers.

The requirements apply to:

1. Plastic materials or articles of any type.
2. Coated materials or articles.
3. Adhesives used in food contact applications.

Exemptions

The requirements do not apply to:

• Storage containers or tanks with a capacity exceeding 10,000 litres.
• Pipelines or tubing connected to such containers that are coated with special heavy-duty coatings.

Key Compliance Requirements

• BFDGE and NOGE are prohibited in the production of food contact materials.
• Materials containing BADGE or its derivatives must include a written declaration of compliance during circulation, except at the retail stage. This is in accordance with Ministry of Agrarian Policy and Food Order No. 1743, dated 2 October 2023.
• Materials must not release regulated substances above the limits specified in the Order.

Purpose and Implementation

The Order aims to protect consumer health by reducing chemical migration from FCMs and ensuring alignment with EU safety standards. Notification under the SPS Agreement confirms that these measures are sanitary and phytosanitary in nature.

The Order was registered with the Ministry of Justice on 29 January 2026, published on 17 February 2026, and will enter into force on 17 May 2026.

By notifying the WTO, Ukraine demonstrates regulatory transparency and strengthens consumer safety, while aligning its FCM regulations with international best practices and EU standards.