Baby Food

The main legislative acts regulating food products, including baby food that is manufactured, placed on the market, or imported (shipped) into the customs territory of Ukraine are:

• the Law of Ukraine “On the Basic Principles and Requirements for Food Safety and Quality”;
• the Law of Ukraine “On State Control of Compliance with Legislation on Food Products, Feed, By-products of Animal Origin, Animal Health and Welfare”;
• the Law of Ukraine “On Information for Consumers Regarding Food Products”;
• and the Law of Ukraine “On Materials and Articles Intended to Come into Contact with Food Products” (which will enter into force on November 19, 2025).

Additional requirements for baby food are established by Order No. 1084 “On Approval of Safety Requirements and Certain Quality Indicators for Baby Food.”

Definitions according to the Law of Ukraine “On the Basic Principles and Requirements for Food Safety and Quality”:

Baby food – a food product intended to meet the nutritional and energy needs of infants and young children, including specially treated water for baby food.

Infant formula – baby food intended for feeding infants during the first months of life that fully meets all nutritional and energy needs until the introduction of complementary foods.

Follow-on formula – baby food for infants that serves as the main liquid component of the diet during the transition to complementary feeding.

Cereal-based baby food – intended to meet the nutritional needs of healthy infants during weaning and of healthy young children as a supplement to the diet and/or as gradual adaptation to normal foods. This includes: porridges and other cereal foods, pasta, rusks, biscuits, crispbreads, and other similar cereal-based foods.

Complementary food – baby food intended for healthy infants during weaning and healthy young children as a supplement to the diet and/or gradual adaptation to regular food.

Water for baby food – drinking water specially treated for consumption by infants and young children, intended for preparing and drinking baby food.

The classification of a product as baby food is based on age criteria: products intended for children under 3 years old fall under this category. Food products for children over 3 years old are not classified as baby food and are subject to general food regulations.

Authorization Documents for Baby Food

When imported into the customs territory of Ukraine, baby food must be accompanied by an international certificate or other document issued by the competent authority of the country of origin or the exporting country.

An international certificate may be a health certificate, international veterinary certificate, or other document issued by the competent authority of the country of origin or exporter certifying the health of the animal and/or the safety of the food product, feed, hay, straw, or by-products of animal origin (according to the Law of Ukraine “On State Control…”).

Before placing baby food on the market, the operator must ensure that the product’s composition, intended use, and target age group comply with national legislation. These requirements cover:

• the mandatory composition for each type of baby food;
• substances prohibited as ingredients in baby food;
• permitted pesticide residues and the list of allowed pesticides;
• the use of vitamins, minerals, amino acids, and other nutrients;
• maximum allowable levels of vitamins, minerals, and micronutrients;
• use of food additives and their maximum concentrations in baby food;
• definition of the consumer’s age category.

Labeling of Baby Food

National legislation sets strict requirements for the labeling of baby food. In addition to general labeling requirements applicable to all food products, specific rules apply, and a list of mandatory additional information must be provided to the consumer.

For example, the law prohibits the use of images, photographs, or wording that idealize baby food. Instead, it requires that labels indicate the age of the child for whom the product is intended and include mandatory warnings regarding consumption.

Other requirements include:

• labeling in Ukrainian;
• nutrition and health claims;
• rules for presentation and rounding of nutritional values;
• and other labeling standards.

Responsibility for compliance with legal requirements regarding safety and specific quality indicators, including labeling of baby food, rests with market operators within the scope of their activities.

Notification (Registration) of Baby Food

Baby food is not subject to state registration. Furthermore, following the repeal of the Law of Ukraine “On Baby Food” in May 2022, the requirement to obtain a sanitary-epidemiological expert opinion for baby food was also abolished.

Currently, before placing baby food on the market, market operators are required to submit a notification of intention to place the product on the market to the competent authority in accordance with the Procedure for Submitting Notification of Intention to Place Baby Food, Food for Special Medical Purposes, and Weight-Control Food Products on the Market, and for Maintaining and Publishing the List of Such Notifications, approved by Order No. 244 of the Ministry of Agrarian Policy and Food of Ukraine dated April 25, 2022 (hereinafter – the Procedure).

At least 10 working days prior to placing baby food on the market, the market operator must submit the notification to the competent authority in electronic or paper form, containing the information as defined in the form provided in the Procedure.

Along with the notification, the market operator must submit:

• a sample of the product label (or sticker);
• the mandatory labeling information in text format;
• any additional information or documents the operator deems relevant.

A baby food product is also considered not previously placed on the Ukrainian market in cases where the mandatory information on the label of a product already available on the market has been changed. In such cases, a new notification must be submitted.

Submission of the notification and its inclusion in the list of notifications is free of charge.

The market operator obtains the right to place the baby food on the market from the date the notification is entered into the register of first-intention notifications.

Food Safety Management System (HACCP)

Each market operator is required to develop and implement an effective Hazard Analysis and Critical Control Points (HACCP) food safety management system to control all potential hazards that may be present in a food product.

The requirements for the development, implementation, and application of continuous procedures based on HACCP principles are approved by Order No. 590 of the Ministry of Agrarian Policy and Food of Ukraine dated October 1, 2012.

Our Services

We professionally provide regulatory and legalization services for dietary supplements, baby food, food for special medical purposes, and weight control products. Our team possesses the required knowledge, experience, and skills, and our specialists are fluent in English.

We offer:

• Evaluation of product composition with in-depth analysis of its formulation and assessment of compliance with legislation and relevant category;
• Review or development of labeling and instructions for use (leaflet);
• Arrangement of laboratory testing to verify compliance with safety requirements and obtain a product safety report;
• Preparation and submission of notification for placing on the market dietary supplements, baby food, food for special medical purposes, and weight-control products;
• Development and implementation of HACCP / ISO 22000 systems;
• Legal and consulting support for manufacturers and importers.