SG 24/23
Ukraine has regulated the migration of lead and cadmium from food contact ceramics. The provisions will become effective on November 19, 2025.
In recent months, Ukraine has issued several pieces of legislation to regulate food contact materials (FCM) and articles. These are:
- Order No. 1734 of September 24, 2022 (n-nitrosamines and N-nitrosatable substances from elastomer or rubber teats and soothers, SafeGuardS 136/22)
- Order No. 1735 of September 24, 2022 (prohibiting triclosan in food contact plastics, SafeGuardS 131/22)
- Law No. 2718-IX of November 3, 2022 (framework legislation on FCM and articles, SafeGuardS 135/22)
- Order No. 2199 of December 5, 2022 (vinyl chloride monomer (VCM) in FCM and articles containing vinyl chloride polymers (PVC) or copolymers, SafeGuardS 14/23)
In January 2023, Ukraine’s Ministry of Health issued Order No. 2373 of December 29, 2022 ‘On approval of the requirements for ceramic products intended for contact with food’ (the Order).
The Order, as amended by Order No. 94 of January 17, 2023 (consolidated text of the Order as amended by Order No. 94 of January 17, 2023), implements European Directive 84/500/EEC on food contact ceramics (consolidated version to 2005). The amended Order contains several important provisions, it:
- Restricts the migration of lead and cadmium from three categories of food contact ceramics
- Details the criteria for satisfying the requirements if the migration of lead and cadmium in a food contact ceramic article does not exceed the quantities by more than 50% (see Table 1 below)
- Details the rules and conditions for determining the migration of lead and cadmium, including their methods of analysis
Highlights of the Order, as amended by Order No. 94 of January 17, 2023, are summarized in Table 1.
Order No. 2373 of December 29, 2022 ‘On the Approval of Requirements for Ceramic Products Intended for Contact with Food’, as amended by Order No. 94 of January 17, 2023.
| Category of Food Contact Ceramic | Requirement Lead | Requirement Cadmium |
|---|---|---|
| PASS | ≤ 0.8 mg/dm² | ≤ 0.07 mg/dm² |
| Category 2: All other articles which can be filled | ≤ 4.0 mg/L | ≤ 0.3 mg/L |
| Category 3: Cooking ware; packaging and storage vessels having a capacity of more than three liters (3 L) | ≤ 1.5 mg/L | ≤ 0.1 mg/L |
| Effective date | November 19, 2025 | |
Table 1
The Order, as amended, contains two important effective dates:
- February 2, 2023, for date of entry into force – the day of its publication in the Official Gazette of Ukraine
- November 19, 2025, for date of applicability – the day Law No. 2718-IX of November 3, 2022 ‘On materials and articles intended to come into contact with food’ becomes applicable
SGS technical experts have extensive knowledge and testing experience in materials and articles in contact with food. They work to ensure that your products meet the appropriate regulations for food contact materials, paving the way for compliance. From overall migration tests to expert advice on emerging regulations, compliance issues and documentation review, SGS is the partner to trust. In the end, it’s only trusted because it’s tested. Discover more on our website.
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