If you import goods into Ukraine in commercial volumes — a container and up — the compliance question has a specific shape, and a lot of what circulates about it is a decade out of date. Certificates are still sold under names that no longer exist in law, while the obligations that do exist land squarely on the importer. This article sets out how the system actually works, so you can tell a required document from a sold one.
What changed: UkrSEPRO no longer exists
Ukraine's old state certification system — UkrSEPRO, with its mandatory certification list — was wound down and ceased to operate from 1 January 2018. Voluntary certification in its place is exactly that: voluntary, sometimes commercially useful, never a legal requirement.
What replaced it is the European model, introduced by the Law on Technical Regulations and Conformity Assessment №124-VIII of 15.01.2015: a set of technical regulations, each adopted by a Cabinet of Ministers resolution and each modelled on the corresponding EU directive.
So the correct first question is not "does this product need a certificate." It is: does any technical regulation cover this product?
How to answer that question
Ukraine has roughly forty technical regulations in force, covering categories rather than individual goods. The ones that catch most imports from China:
- Low-voltage electrical equipment — Cabinet resolution №1067 of 16.12.2015, covering equipment for 50–1000 V AC or 75–1500 V DC. That is most mains-powered products.
- Electromagnetic compatibility — Cabinet resolution №1077 of 16.12.2015, built on EU Directive 2014/30/EU, covering essentially anything electronic.
- Machinery, toys, personal protective equipment, radio equipment, construction products, pressure equipment, restriction of hazardous substances, and others.
Note that one product routinely falls under several at once: a mains-powered radio-controlled device sits under low-voltage, EMC and radio equipment simultaneously, and each brings its own requirements. Establishing the full list is the work — not obtaining the paper afterwards.
Who may draw up the declaration
The declaration of conformity is drawn up and signed by the manufacturer, its authorised representative, or the supplier placing the product on the market — and that representative or supplier must be a resident of Ukraine.
This is the operative point for anyone buying in China. A Chinese factory cannot be the responsible person in Ukraine. In practice, the importer signs, which means the importer holds the technical file and answers to market surveillance. You are not buying compliance from your supplier; you are collecting the evidence that lets you declare it yourself. That principle runs through the whole subject — see which documents you actually need to sell goods imported from China.
Registering the declaration is voluntary
Registration of a declaration with a conformity assessment body is done on a voluntary basis, at the applicant's wish. It is not a legal precondition for placing goods on the market.
This matters commercially, because "registration of your declaration" is routinely sold as though it were mandatory. Sometimes registration is still worth having — a counterparty, a marketplace or a tender may ask for a registered document. But it should be a business decision, not a purchase made under a false impression of legal necessity.
When you need a designated body
Technical regulations use conformity assessment modules, inherited from the EU system. For a large share of products the module allows internal production control: the manufacturer performs testing and compiles the technical file, no third party involved. Other modules require a designated conformity assessment body — type examination, quality-system assessment, or verification — typically for higher-risk categories: certain machinery, PPE, pressure equipment, some medical and gas products.
Which module applies is written in the regulation itself, which is why reading the applicable regulation, rather than asking a certification company what they can sell, is the cheaper route.
The conformity mark
The Ukrainian conformity mark is defined by Cabinet resolution №1184 of 30.12.2015: a circle open on the right-hand side containing a stylised trefoil. It is applied by the manufacturer or its authorised representative, so that it is visible, legible and indelible.
That resolution was amended by Cabinet resolution №846 of 23.07.2024, which introduced different mark forms for sectors covered and not covered by the future agreement with the EU — the reason for which is in the next section.
What the ACAA agreement will change
The ACAA — the Agreement on Conformity Assessment and Acceptance of Industrial Products, informally the "industrial visa-free regime" — will let goods move between Ukraine and the EU in covered sectors on the same terms as between EU member states. Ukraine has moved to practical negotiations, with a realistic launch in 2027, and the first stage is expected to cover three sectors: machinery, low-voltage equipment and electromagnetic compatibility.
For importers this is worth planning around rather than waiting on: those three sectors are exactly where most imported electrical goods sit, and evidence prepared to EU harmonised standards today transfers far more cleanly than evidence assembled ad hoc.
What this means when the goods come from China
- Specify the standards in the order. Ask for testing against the harmonised European standards that underpin the Ukrainian regulations, not against GB standards only. This belongs in the technical spec sheet for the factory.
- Check the report describes your product. Same model, same configuration, current standard edition. Component substitution invalidates it — see DFM and the changes factories propose.
- Get the labelling right at the factory. Rating plate, markings, and the manual in Ukrainian are part of conformity, not packaging decoration — see packaging development in China.
- Assemble the technical file before arrival, not after a market surveillance inspection asks for it.
- Verify the paperwork is real. See how to check whether a Chinese certificate is genuine.
Checklist before shipment
- Full list of technical regulations that apply to the product — all of them, not the first one found
- Conformity assessment module identified, and a designated body engaged if the module requires one
- Test reports naming your model, the standard and its edition, from an identifiable accredited laboratory
- Technical file assembled: drawings, schematics, BOM, risk assessment, test reports, manual
- Declaration of conformity drawn up by a Ukrainian resident entity
- Conformity mark and rating plate applied correctly at the factory, verified by photograph
- Customs documentation consistent with all of the above — see import documents from China
The old question — "which certificate do I buy?" — has no answer in the current system, because nobody sells the thing that makes you compliant. You assemble it. What is for sale is testing, assessment and advice; the responsibility stays with whoever puts the product on the market.
Handling conformity as part of the import
We identify which regulations apply before the specification is frozen, put the right standards into the factory documentation, check existing reports against accreditation registries, arrange testing where reports are missing, and assemble the technical file the Ukrainian importer must hold. Seven years, 3,500+ deliveries, 340+ verified suppliers — real projects are in our case studies.
Start with document support or foreign trade consulting.
