ness will depend on how accessible, relia ble and efficiently maintained they are in practice. “Predictable registration and reli able state registers are essential,” says Grygorenko. “Companies and farmers need to know which products are authorised, under which conditions they may be used, and what obligations apply throughout the chain.” The law also regulates the placing of GMOs and GM products on the market. It includes provisions on declarations, noti fications related to production or cultiva tion, post-registration monitoring, and the parallel use of GMOs, GM products and products that do not contain GMOs. These are important issues for supply chains where conventional, organic and GM-related products may need to be handled separately and transparently. LABELLING, THRESHOLDS AND TRACEABILITY The new law also sets out labelling require ments for GMOs and GM products, including food, feed and products that are not food or feed. It regulates the use of “With GMO” and “GMO-free” labels and defines threshold values for accidental and technically unavoidable GMO resi dues. According to the overview of the law, these thresholds cannot be less than 0.1% and cannot exceed 0.9% for certain types of products. This element is highly relevant for trade and market confidence. Labelling and traceability rules can help avoid confusion, support enforcement and give operators clearer responsibilities. Grygorenko describes these crop-spe cific restrictions as an important part of the transition. “They show that Ukraine is introducing a regulatory framework but also applying political and practical safeguards for certain crops,” she says. “The details of implementation will be very important for the seed sector.” For companies, breeders, farmers and regulators, several practical questions remain. How will these bans interact with research permits? What will be allowed for confined or controlled research? How will operators distinguish between cultivation, testing and other activities? What will happen after the five-year period for sugar beet and rapeseed? And how will these provisions be communicated to farmers and companies? These questions show why the transitional provisions will be central to how the law is understood and applied by the sector. PREPARING FOR EU MEMBERSHIP One of the most significant provisions relates to Ukraine’s future EU member ship. According to the overview, from the moment Ukraine acquires the status of an EU Member State, the registration of all GMOs not permitted in the EU will be cancelled. The relevant information in the State Register of GMOs will lose its status as official information, and applications for the state registration of GMOs under Ukrainian law will be returned without consideration. This provision makes the law directly relevant to Ukraine’s EU integration pro cess. It creates a bridge between Ukraine’s national system and the future application of EU rules. For companies, this means that regu latory planning in Ukraine cannot be sep arated from the EU framework. Products that may be considered under Ukrainian rules before accession may face a different legal position once Ukraine becomes an EU member state. “The EU membership provision is very important,” Grygorenko says. “It means that Ukraine is already preparing its regu latory system for future alignment with EU rules. For the seed sector, this creates a need to look not only at the Ukrainian law itself, but also at how it will connect with the EU framework over time.” At the same time, they must be work able in real supply chains, particularly in a country with significant agricultural pro duction, storage, transport and export flows. For seed companies, farmers, traders and processors, the practical challenge will be to understand how the rules apply to different products and at different stages of the chain. Clear guidance will be needed on documen tation, testing, thresholds, declarations and the handling of accidental presence. According to Grygorenko, this is why implementation will matter as much as the legal text itself. “Labelling and traceability are not only consumer information tools,” she says. “They are also essential for market functioning. The rules must be clear enough for enforcement authorities, but also prac tical enough for companies, farmers and traders to apply.” CROP-SPECIFIC RESTRICTIONS The transitional provisions are among the most sensitive parts of the law. The over view provided by SAU indicates that the law includes an indefinite ban on the cul tivation of genetically modified maize in open systems. It also includes a five-year ban on the cultivation of genetically mod ified sugar beet and rapeseed in open sys tems, except for research in an open system with the relevant permit. These crop-specific provisions deserve careful attention. Maize, sugar beet and rapeseed are all important crops in European agriculture, and they are also politically sensitive in GMO discussions. By including specific cultivation bans, Ukraine is not simply creating a general regulatory pathway. It is also setting clear boundaries for certain crops during the transition. Agricultural trial plots in Ukraine used for plant breeding, variety evaluation and seed production. New GMO legislation establishes permit and oversight requirements for open-system research and testing. Photo: SPFE Company MAIS. 28 I SEED WORLD EUROPE I SEEDWORLD.COM/EUROPE | OCTOBER 2026
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