26 I SEED WORLD EUROPE I SEEDWORLD.COM/EUROPE | OCTOBER 2026 U kraine is preparing for a major reset of its GMO legislation. In September 2026, a new law on the state regulation of genetic engineer ing activities and the control of genetically modified organisms (GMO) and products on the market is scheduled to enter into force. For the seed sector, the law is more than a technical update. It is part of a wider effort to modernise Ukraine’s regulatory framework, strengthen biosafety oversight and prepare the country for deeper align ment with the European Union. The law, adopted in August 2023, defines the legal and organisational prin ciples for regulating genetic engineering activities, ensuring environmental, genetic, food and biological safety, and controlling the placing of GMOs and GM products on the market. It consists of 12 chapters, 43 arti cles and final and transitional provisions, covering everything from closed-system research to open-system testing, state regis ters, labelling, market placement, monitor ing, transboundary movement, laboratory requirements, state control and penalties. For Ukraine, the timing matters. The country remains a major agricultural pro ducer and exporter, while at the same time moving through a demanding process of legal convergence with the EU. In that context, GMO rules are not only about technology. They are also about trade, public trust, market access, enforce ment capacity and the credibility of the regulatory system. According to Siuzana Grygorenko, executive director of the Seed Association of Ukraine, the new law should be seen in that broader context. “Ukraine needs a modern, transparent and predictable frame work for genetic engineering and GMO regulation,” she says. “This is important for biosafety, but also for legal certainty, investment, research and Ukraine’s contin ued integration with the European Union.” Ukraine’s GMO Reset The law distinguishes between genetic engineering activities in closed systems and the handling of GMOs in open systems. Closed-system activities are subject to dif ferent requirements depending on the risk level. The law identifies four risk levels and provides for declarations or permits depending on the level of risk involved. Open-system activities, including research and testing, require specific conditions and applications for permits. This is particularly relevant for research organisations, breeders and companies that may be involved in biotechnology, trait development, testing or product assessment. The law provides a more defined pathway, but it also creates new administrative and compliance obligations. Grygorenko stresses that the law should be understood as a framework law rather than as a complete implementation manual. “It creates the architecture for regulation, from research and testing to registration, labelling and state control,” she says. “For the seed sector, the practi cal question will be how this framework is implemented through bylaws and adminis trative procedures.” REGISTRATION, REGISTERS AND MARKET PLACEMENT The law establishes several state regis ters governing GMO activities, including the State Register of Subjects of Genetic Engineering Activity, the State Register of Permits for Conducting Research and Testing of GMOs in an Open System, and the State Register of GMOs. It also outlines the GMO registration process, including application requirements and procedures for review, approval, suspension and can cellation. For the seed sector, these registers could become central tools for legal cer tainty. They can clarify who is authorised to conduct certain activities, which permits have been granted, and which GMOs are officially registered. However, their useful A NEW LAW WILL RESHAPE BIOSAFETY, REGISTRATION AND MARKET RULES AS UKRAINE MOVES CLOSER TO THE EU. BY: MARCEL BRUINS A FRAMEWORK FOR THE FULL GMO CHAIN One of the most important features of the new law is its breadth. It does not focus only on whether a GMO may or may not be cul tivated or placed on the market. Instead, it creates a wider regulatory structure for how genetic engineering activities are car ried out, how GMOs are assessed and reg istered, how GM products are labelled and traced, and how compliance is controlled. Siuzana Grygorenko, executive director of the Seed Association of Ukraine (SAU) “Ukraine is already preparing its regulatory system for future alignment with EU rules.”
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