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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