Market requirements · UA
Ukraine
Ukraine regulates medicines under the Law on Medicinal Products of 4 April 1996, enforced by the State Service on Medicines and Drugs Control, and a separate licence is required to import medicines at all. Classification turns on a single binary a buyer can check before shipping: whether the product is entered in the State Register of Medicines and permitted for use in Ukraine. Martial law briefly replaced the import licence with a self-declaration, but that window closed on 13 July 2022 and import reverted to a full licence on a general basis.
| Tell us the compounds you need for Ukraine. | Ask about Ukraine |
The regime
How compounds are classified in Ukraine
| Governing law | The operative act is Law No. 123/96-VR of 4 April 1996 on medicinal products, read with the law on licensing of types of economic activity. The substantive conditions sit in Cabinet of Ministers Resolution No. 929 of 30 November 2016, which approves the licensing conditions for manufacture, wholesale and retail trade, and import of medicines other than active ingredients. A replacement statute, Law No. 2469-IX of 28 July 2022, has been adopted but is deferred, and the 1996 law loses force on 1 January 2027, so a buyer signing multi-year terms is contracting across a recodification. |
|---|---|
| What determines classification | The regulator and the tax service both work from the State Register of Medicines rather than from the seller's product description. The tax service position of 19 February 2024 sets the test explicitly: a product qualifies for treatment as a medicine only if it is allowed for production and use in Ukraine and included in the State Register, and if either condition fails the transaction is taxed in the generally established manner. An import licence is issued against a named list of medicines annexed to it, so a product absent from that annex is outside the licence even where the importer is licensed. There is no published Ukrainian position treating research-use labelling as a category of its own. |
| EU candidate, deep free trade area, and martial law | Ukraine operates the deep and comprehensive free trade area under the Association Agreement and is aligning medicines law to the European framework, which is what the deferred 2022 statute is for. Martial law changed procedure, and the direction of travel matters: Resolution No. 314 of 18 March 2022 allowed several licensed activities to proceed on a declaration, and Resolution No. 778 of 7 July 2022 amended it so that from 13 July 2022 import, wholesale and retail trade of medicines is again carried out on a general basis, with declarations already filed valid for six months only. Separately, in April 2022 the government approved emergency registration for medicines supplied during martial law without the right to sell, allowed electronic dossiers, extended expiring certificates and permitted import of registered medicines in foreign packaging. Read martial law as having relaxed paperwork and packaging, not the licence. |
| Prescription and controlled substances | Not established for named peptides. Prescription or over-the-counter status follows the entry for the specific product in the State Register rather than a standing substance list, so it must be checked product by product. Narcotic drugs, psychotropic substances and precursors are separately controlled under Resolution No. 770 of 6 May 2000 and require their own licence, and no published instrument was found naming research peptides in that schedule. Ukraine has anti-doping legislation from 2017, but it could not be verified on an authoritative source that it sets criminal thresholds for named peptide substances, so no position is asserted. |
| Enforcement posture | Active, and joint with police. On 27 April 2026 the regulator reported that the National Police strategic investigations department in Zaporizhzhia Oblast, working with regional offices in Zaporizhzhia and Chernivtsi, dismantled a channel supplying medicines from abroad in breach of procedure and selling them through a pharmacy, with charges filed against a pharmacy manager and a hospital department head. The same notice closes by reminding business entities to comply strictly with the licensing conditions approved by Resolution No. 929, which is the regulator naming the instrument it enforces. |
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Your obligations
What a buyer in Ukraine needs settled
- Obtain a licence for the import of medicines before any shipment, and confirm that every product you intend to sell appears on the list annexed to that licence.
- Verify each product's entry in the State Register of Medicines before ordering, because an unregistered product cannot lawfully be placed on the market and cannot be corrected at the border.
- Budget 7 per cent import VAT only where the product is registered and permitted for use in Ukraine, and budget the standard 20 per cent for anything else.
- Appoint an authorised person meeting the qualification and experience requirements of Resolution No. 929 and name that person in your licence file.
- Keep import, quality-control and distribution records to good distribution practice standard, including the quality conclusion for each imported consignment.
- Do not rely on any martial-law declaration or simplified route for commercial import, because the declarative regime for medicines import ended on 13 July 2022.
We will ask about this at enquiry. We check the authorisations your activity requires before quoting, and we confirm the position per compound rather than for the market as a whole.
Sources
Check this yourself
Every position above traces to a dated public document. The authority, the document, the date and the link are below.
| Authority and document | Date | Link |
|---|---|---|
| Verkhovna Rada of Ukraine Law No. 123/96-VR on Medicinal Products | 1996 | zakon.rada.gov.ua/laws/show/123/96-%D0%B2%D1%80?lang=en |
| Verkhovna Rada of Ukraine Law No. 2469-IX on Medicinal Products, deferred, replaces the 1996 act from 1 January 2027 | 2022 | zakon.rada.gov.ua/laws/show/2469-20 |
| Cabinet of Ministers of Ukraine Resolution No. 929, licensing conditions for manufacture, wholesale, retail and import of medicines | 2016 | zakon.rada.gov.ua/laws/show/929-2016-%D0%BF |
| State Service on Medicines and Drugs Control Licensing of import, wholesale and retail trade of medicines during martial law from 13 July 2022 | 2022 | www.dls.gov.ua/en/dicls_news/peculiarities-of-licensing-of... |
| State Tax Service of Ukraine VAT on supply of medicines, 7 per cent on registered medicines and 20 per cent otherwise | 2024 | tax.gov.ua/en/new-about-taxes--hotlines-/757104.html |
| State Service on Medicines and Drugs Control Enforcement notice, Zaporizhzhia region, illegal import and sale of unregistered medicines | 2026 | www.dls.gov.ua/en/news/in-zaporizhzhia-region-the-national... |
Links go to the issuing body wherever one exists. Positions change. If you are relying on any of this, check the source rather than this page.
Market brief
Take the Ukraine brief as a PDF
The regime, the buyer obligations and all 6 sources, dated and linked, in one document you can forward.
Nearby
Eastern Europe and nearby markets
Buyers supplying one of these usually supply the others. The requirements are not the same.
Scope
How to use this page
A summary of the published regulatory position in Ukraine as at 2026-08-20, written for procurement teams deciding how to source. Every source is dated and linked so it can be checked at origin.
It is not legal advice. Full terms of supply, including where responsibility sits, are set out in our terms of supply.
Questions
Supplying into Ukraine
Do you supply into Ukraine?
We supply businesses that hold the authorisations their activity requires. Whether a specific compound can be supplied into Ukraine depends on that compound and on your authorisations, and we confirm it per compound at the enquiry stage.
Who carries the compliance obligation?
The importer of record and the party placing the product on the market, which is the buyer. We supply the batch documentation that supports your file. We cannot hold your authorisations for you.
How current is this page?
It was reviewed on 2026-08-20 and is scheduled for review again on 2026-11-18. Every source is dated and linked, so you can check the original.
We already supply into Ukraine. What changes if we source from you?
The batch documentation. You receive a Certificate of Analysis per batch, which can be issued under your own brand. The import and market-placing responsibilities stay where they are.
Is this legal advice?
No. It is a summary of the regulatory positions those authorities have published, as at the review date above. Take advice in your own market before you rely on it.
Enquire about supply into Ukraine
Tell us the compounds and your authorisations. We confirm per compound before anything ships.