With the launch of the electronic cosmetic product notification portal on December 1, the market has effectively moved from the preparatory stage to the practical implementation of the requirements of the Technical Regulation on cosmetic products. For manufacturers and importers, this means that full regulatory readiness of a product must be ensured before placing it on the Ukrainian market.
In practice, the focus has now shifted to the quality of regulatory documentation. This includes the accuracy of product composition and labeling, the availability and validity of the Product Information File (PIF), the Cosmetic Product Safety Report (CPSR), confirmation of Good Manufacturing Practice (GMP), and the designation of a Responsible Person. These elements are critical for safe market entry and for effective interaction with market surveillance authorities.
Following the launch of the portal, companies have been actively clarifying practical aspects of data submission: product identification data, responsible and contact persons, country of origin, shade variations, specific characteristics of ingredients (including restrictions, physical form, and the presence of nanomaterials), as well as uploading packaging artwork. Cosmetic product notification is therefore no longer a formal step but an integral part of a company’s ongoing regulatory compliance function.
Our recommendation for companies during the transition period until 3 August 2026 is not to postpone preparation. Conduct a regulatory documentation audit, identify and address gaps in the PIF and CPSR, and align labeling and technical product data prior to submitting a notification. This proactive approach significantly reduces regulatory risks related to market placement, sales continuity, and potential inspections in 2026.
Regulatory Support by Pharma Navigation
Pharma Navigation provides comprehensive support for cosmetic product notification, including:
- consultations on regulatory requirements;
- preparation of the product information file (PIF) and Cosmetic product safety report (or adaptation of existing documentation);
- ingredient and formulation assessment;
- designation of the Responsible Person;
- development of labelling and packaging design;
- submission of notification via the Ministry of Health portal;
- assessment of compliance with other applicable technical regulations.
Pharma Navigation approaches cosmetic product notification as a structured regulatory process, supporting projects both at the stage of initial documentation development and where existing PIF and CPSR require review or adaptation. Our practical experience, including direct cooperation with foreign manufacturers and professional communication in English, ensures accurate preparation and alignment of documentation with Ukrainian regulatory requirements.