Business urges to reduce the deadline for issuing sanitary and epidemiological conclusions of the State Service of Ukraine on Food Safety and Consumer Protection to 10 working days

11/ 11/ 2022

Business is grateful to the Government for the adoption of Resolution No. 314 back in March. The document establishes that the validity period of permit documents is extended for the period of martial law, and provides that during the period of martial law, instead of obtaining separate permit documents, entrepreneurs can simply submit declarations of proceedings economic activity. Meanwhile, Resolution No. 314 stipulates that 3 months after the end of martial law, the business must have all unreceived permit documents, including the conclusions of the state sanitary and epidemiological examination. However, some specialists are already interpreting the absence of Conclusions, which are, for example, part of the technical documentation for detergents, as a violation of the requirements of the profile technical regulation, which in the end may lead to fines and misunderstandings in communications with state authorities during inspections. After all, business does not fully understand how to interpret the legislation, and the lack of specifics, in fact, causes concern. Accordingly, some distributors of non-food products have long begun to demand Conclusions from manufacturers and importers and often refuse to supply such products to the market without them. Therefore, the issue of obtaining Conclusions from the State Service of Ukraine on Food Security and Consumer Protection remains extremely relevant for business. Back in May, the State Service of Ukraine on Food Security and Consumer Protection announced the resumption of accepting applications for the issuance of Conclusions. However, businesses report constant and very long (more than several months) delays in receiving Conclusions, which negatively affects the normal implementation of business processes. However, businesses report constant and very long (more than several months) delays in receiving Conclusions, which negatively affects the normal implementation of business processes. The situation is further complicated because the deadline for issuing permit documents by the licensing authorities during martial law in Ukraine has been suspended due to the adoption of Government Resolution No. 165. Therefore, the companies actually, on the one hand, do not have the opportunity to draw the attention of the State Production and Consumer Service to their non-compliance with the legally defined deadlines for issuing Conclusions. However, on the other hand, without the relevant documents, businesses cannot continue to operate normally. Therefore, the European Business Association appeals to the Prime Minister of Ukraine Denys Shmyhal, and the Government to consider the possibility and reduce the deadline for issuance to 10 working days. It is extremely important for businesses not only to obtain Conclusions but also to simplify the procedure for signing Conclusions, making it as transparent and controlled as possible.

Meanwhile, Resolution No. 314 stipulates that 3 months after the end of martial law, the business must have all unreceived permit documents, including the conclusions of the state sanitary and epidemiological examination.

However, some specialists are already interpreting the absence of Conclusions, which are, for example, part of the technical documentation for detergents, as a violation of the requirements of the profile technical regulation, which in the end may lead to fines and misunderstandings in communications with state authorities during inspections. After all, business does not fully understand how to interpret the legislation, and the lack of specifics, in fact, causes concern.

Accordingly, some distributors of non-food products have long begun to demand Conclusions from manufacturers and importers and often refuse to supply such products to the market without them. Therefore, the issue of obtaining Conclusions from the State Service of Ukraine on Food Security and Consumer Protection remains extremely relevant for business.

Back in May, the State Service of Ukraine on Food Security and Consumer Protection announced the resumption of accepting applications for the issuance of Conclusions.

However, businesses report constant and very long (more than several months) delays in receiving Conclusions, which negatively affects the normal implementation of business processes.

The situation is further complicated because the deadline for issuing permit documents by the licensing authorities during martial law in Ukraine has been suspended due to the adoption of Government Resolution No. 165. Therefore, the companies actually, on the one hand, do not have the opportunity to draw the attention of the State Production and Consumer Service to their non-compliance with the legally defined deadlines for issuing Conclusions. However, on the other hand, without the relevant documents, businesses cannot continue to operate normally.

Therefore, the European Business Association appeals to the Prime Minister of Ukraine Denys Shmyhal, and the Government to consider the possibility and reduce the deadline for issuance to 10 working days. It is extremely important for businesses not only to obtain Conclusions but also to simplify the procedure for signing Conclusions, making it as transparent and controlled as possible.