Head of Medical Law Practice
Specializes in medical, corporate, and migration law. Has extensive experience working with medical and pharmaceutical businesses, particularly in licensing, circulation of medicines, and comprehensive legal support of healthcare institutions, including corporate, tax, and employment matters, as well as market entry projects of foreign companies into Ukraine.
Cosmetic notification
Are you planning to enter the Ukrainian market with a new cosmetic brand or launch your own production? According to the Technical Regulation on cosmetic products, a mandatory stage before placing goods on the market is cosmetic notification in the System of Electronic Notification (SEN ICP).
In this article, we will explain how to go through this procedure without mistakes, avoid fines and successfully register the product.
What is notification of cosmetic products?
Notification is the provision of detailed data about a cosmetic product to state market surveillance authorities through a special electronic platform of the Ministry of Health, which was launched in Ukraine in December 2025.
Important: The information must be notified before placing the product on the market, that is, before the first making available of the product on the Ukrainian market.
Who is the “Responsible Person” and why is it important?
Each cosmetic product must have an appointed responsible person (RP) — a legal entity or individual entrepreneur who is a resident of Ukraine. It is this person who bears legal responsibility for the product’s compliance with the regulation and carries out the notification.
The responsible person may only be a resident of Ukraine (a legal entity or individual entrepreneur). Depending on the origin of the product, this role is performed by:
- for manufacturers in Ukraine, if the cosmetics are manufactured in Ukraine and are not exported with subsequent return, the responsible person by default is the resident manufacturer itself;
- for importers, for each imported cosmetic product, the responsible person is the importer;
- an appointed person (by authorization). The manufacturer or importer may appoint another person (for example, a consulting company or distributor) as the responsible person on the basis of written authorization. In such a case, the appointed person must provide their written consent.
Step-by-step algorithm for notification in SEN ICP
Step 1: Authentication in the system
Access to the account is carried out using the QES (Qualified Electronic Signature) of the manager. The system automatically verifies the data in the USR.
For business: The QES of the representative of the legal entity or individual entrepreneur is used.
For authorized employees: The manager may grant access rights to employees (for example, a certification manager or lawyer).
Step 2: Appointment of a contact person
The responsible person must enter data about the contact person whom the controlling authorities may contact if necessary. It is necessary to indicate full name, position, postal address in Ukraine, phone number and email.
Step 3: Preparation of the Safety Report (CPSR)
Before starting the notification, you must have a ready Cosmetic Product Safety Report (CPSR).
The report consists of Parts A and B. It is important to note that Part B must be signed by a qualified expert (assessor) with the relevant higher education (pharmacy, medicine).
Although the report itself is not uploaded to the system, the responsible person confirms its availability and the product’s compliance with safety requirements.
Step 4: Entering product data
A draft is created in the system, where the following fields are filled in:
- Product name: Must include the brand, line and function in Ukrainian. Registered trademarks are not translated (information is entered according to the principle of “transliteration”).
- Category: Selection from a three-level directory (for example, skin care products — face masks).
- Formula: You can choose a standard “formula framework” or specify your own with exact concentrations or ranges of ingredients (according to INCI).
- Graphic files: A labeling file is uploaded (label or sticker layout), which the buyer in Ukraine will see.
Step 5: Final notification
After checking all data, the product receives the status “Notified” and a unique identifier.
Frequently asked questions from importers and manufacturers of cosmetic products
Is it necessary to translate the composition (ingredients)?
No, the list of ingredients is indicated in Latin according to the INCI nomenclature.
Is it necessary to notify different volumes?
If the formula is identical, different volumes (for example, 30 ml and 100 ml) do not need to be notified separately.
Products with shades:
If a lipstick or nail polish has the same base but different pigments, they are notified as one product with a list of shades.
Professional assistance in cosmetic notification
The procedure requires deep knowledge of the chemical composition, labeling requirements and technical nuances of working with SEN ICP. An error in the formula or the status of CMR substances may lead to the blocking of product sales.
We offer comprehensive support:
- providing explanations and recommendations regarding the specifics of notification of your cosmetic products specifically;
- support in the development of the Safety Report;
- technical entry of data into the notification system;
- audit of labeling for compliance with the language law and technical regulation.
Contact us today to ensure the legal start of your cosmetic business in Ukraine!
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1 question
Do you work with imported products?
2 question
Are you planning to launch a new brand or a new product line?
3 question
Do you need permits for your products or business?
Is notification of cosmetic products mandatory in Ukraine?
Yes. Before placing cosmetic products on the market in Ukraine, it is necessary to undergo the notification procedure and enter information about the product into the System of Electronic Notification (SEN ICP).
Who can be the responsible person for cosmetic products?
The responsible person can only be a resident of Ukraine — a legal entity or an individual entrepreneur. For Ukrainian products, this is usually the manufacturer; for imported products, it is the importer or another person appointed by written authorization.
Is a Cosmetic Product Safety Report (CPSR) required for cosmetic notification?
Yes. The availability of a CPSR is a mandatory requirement. Although the report itself is not uploaded to the system, the responsible person confirms its availability and the product’s compliance with safety requirements.
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