OCTOBER 2026  |  SEEDWORLD.COM/EUROPE  I  SEED WORLD EUROPE   I   29
Such legal transitions are common 
in accession processes, but GMO regula­
tion is a particularly sensitive area because 
it touches authorisation, cultivation, 
imports, labelling and public confidence. 
Candidate countries often need to manage 
a transition between national systems and 
future EU obligations. But in the GMO 
field, where authorisation, cultivation, 
import, labelling and public perception are 
all sensitive, the transition requires careful 
communication.
ENFORCEMENT AND 
INSTITUTIONAL CAPACITY
The new law also addresses state control and 
liability. It provides for state control over 
compliance with biosafety requirements 
in closed systems, the handling of GMOs 
during open-system research and testing, 
and the placing of GMOs and GM prod­
ucts on the market. It also sets out response 
measures and fines for violations, including 
breaches of biosafety requirements, rules for 
open-system handling, and requirements 
for placing GMOs and GM products on 
the market.
This enforcement dimension is crit­
ical. A modern law can only function if 
authorities have the capacity, expertise and 
resources to implement it. That includes risk 
assessment, laboratory testing, inspection, 
border controls, registers, monitoring and 
communication with operators.
The law provides for the State 
Commission for GMO Risk Assessment 
and a Scientific and Methodological Center 
for Testing of GMOs. It also sets require­
ments for laboratories conducting GMO 
research and testing, including accredita­
tion and obligations to provide information 
on testing methods and results. These insti­
tutional elements could become the back­
bone of the new system.
For Ukraine’s seed sector, the main 
question will be whether implementation is 
predictable and proportionate. Overly slow 
or unclear procedures could create uncer­
tainty. At the same time, weak enforcement 
would undermine trust in the system.
Grygorenko says the success of the law 
will ultimately depend on how it works in 
practice. “Ukraine will need clear proce­
dures, competent institutions, accredited 
laboratories and constructive dialogue with 
the seed sector and other stakeholders.” 
WHAT SHOULD THE SEED 
SECTOR WATCH NEXT?
The new GMO law marks an important 
step in Ukraine’s regulatory development. 
But the law itself is only the starting point. 
The next phase will be shaped by bylaws, 
implementing procedures, institutional 
readiness and clear communication with 
stakeholders.
For seed companies and breeders, sev­
eral questions will deserve close attention. 
Which bylaws have already been adopted, 
and which are still pending? How will 
applications and permits be handled in 
practice? What transitional rules apply to 
existing activities or products? How will 
the cultivation bans be interpreted? How 
will testing and labelling requirements be 
enforced? And how will Ukraine manage 
the link between its national framework and 
future EU membership?
The answers will matter not only 
for biotechnology. They will also matter 
for trust in the regulatory environment. 
Ukraine’s seed sector has shown resilience 
under extremely difficult circumstances 
since the Russian invasion of Ukraine. 
As the country continues its path toward 
European integration, regulatory clarity 
will be essential for investment, innovation 
and trade.
For Grygorenko, the law is part of a 
broader transformation. “This law is part of 
a broader transformation of Ukraine’s agri­
cultural and regulatory system,” she says. 
“For the seed sector, the priority is to ensure 
that the rules are clear, science-based, 
enforceable and aligned with Ukraine’s 
future as part of the European market.”
The new GMO law therefore deserves 
attention across Europe. It is a national 
law, but it sits within a much larger story: 
Ukraine’s agricultural future, its relation­
ship with the EU, and the way Europe 
manages innovation, biosafety and market 
confidence in the years ahead. 
“Companies and farmers need 
to know which products 
are authorised, under which 
conditions they may be used, 
and what obligations apply 
throughout the chain.”
Certified seed packages at a Ukrainian processing facility. Ukraine’s new GMO framework introduces 
labelling, documentation and traceability requirements across the agricultural supply chain. Photo: NPZ.

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