Investments during the war should be for the benefit of the country’s economy, not to put additional burden on business – EBA

11/ 04/ 2024

On March 13, 2024, a draft CMU resolution on the Procedure for Food Fortification was published for public discussion on the official website of the Ministry of Health. For your understanding, fortification is the addition (saturation) of food with vitamins. Thus, the draft Resolution plans to determine the levels of consumption of certain food products to which vitamins and/or minerals can be added. The Procedure for Food Fortification, which is proposed to be approved, defines the grounds and procedure for introducing mandatory fortification of food with certain vitamins and/or minerals. In addition, the draft Procedure stipulates that mandatory fortification of food products by market operators is introduced by the Cabinet of Ministers of Ukraine by issuing an order in accordance with this Procedure. Therefore, it is assumed that fortification may become mandatory for all producers. In turn, business representatives note that the introduction of food fortification requires serious investments in the modernization of production lines. This may create significant financial difficulties for companies and the food industry, which already suffer significant losses during wartime. In this regard, there is a risk that not all food industry entities will be able to modernize their production facilities to implement product fortification, especially now, at a time when business is already challenging. This requires reformatting and changing equipment at factories, updating recipes, changing labels, etc. As a result, the inability to comply with the established requirements may lead to such negative consequences as the closure of enterprises, loss of jobs, losses for the industry and reduced tax payments to the state budget. In addition, it may lead to higher prices for products and affect the financial position of the end consumer. Moreover, the introduction of mandatory fortification of certain products manufactured in Ukraine could potentially lead to the loss of foreign markets where there is a demand for unfortified products, as well as to an unreasonable financial burden not only on business entities but also on consumers. The European Business Association appeals to the Prime Minister of Ukraine Denys Shmyhal, Minister of Agrarian Policy Mykola Solskyi, and Minister of Health Viktor Liashko to provide a version of the draft decree that will introduce mandatory food fortification for review. In addition, it should explain which food products will be subject to mandatory fortification, whether business entities will receive compensation or support from the state for the introduction of mandatory food fortification, etc. Therefore, the business insists on holding an open discussion with business representatives to discuss in detail the initiative on mandatory food fortification.

On March 13, 2024, a draft CMU resolution on the Procedure for Food Fortification was published for public discussion on the official website of the Ministry of Health.

For your understanding, fortification is the addition (saturation) of food with vitamins.

Thus, the draft Resolution plans to determine the levels of consumption of certain food products to which vitamins and/or minerals can be added. The Procedure for Food Fortification, which is proposed to be approved, defines the grounds and procedure for introducing mandatory fortification of food with certain vitamins and/or minerals. In addition, the draft Procedure stipulates that mandatory fortification of food products by market operators is introduced by the Cabinet of Ministers of Ukraine by issuing an order in accordance with this Procedure. Therefore, it is assumed that fortification may become mandatory for all producers.

In turn, business representatives note that the introduction of food fortification requires serious investments in the modernization of production lines. This may create significant financial difficulties for companies and the food industry, which already suffer significant losses during wartime. In this regard, there is a risk that not all food industry entities will be able to modernize their production facilities to implement product fortification, especially now, at a time when business is already challenging. This requires reformatting and changing equipment at factories, updating recipes, changing labels, etc.

As a result, the inability to comply with the established requirements may lead to such negative consequences as the closure of enterprises, loss of jobs, losses for the industry and reduced tax payments to the state budget. In addition, it may lead to higher prices for products and affect the financial position of the end consumer.

Moreover, the introduction of mandatory fortification of certain products manufactured in Ukraine could potentially lead to the loss of foreign markets where there is a demand for unfortified products, as well as to an unreasonable financial burden not only on business entities but also on consumers.

The European Business Association appeals to the Prime Minister of Ukraine Denys Shmyhal, Minister of Agrarian Policy Mykola Solskyi, and Minister of Health Viktor Liashko to provide a version of the draft decree that will introduce mandatory food fortification for review. In addition, it should explain which food products will be subject to mandatory fortification, whether business entities will receive compensation or support from the state for the introduction of mandatory food fortification, etc.

Therefore, the business insists on holding an open discussion with business representatives to discuss in detail the initiative on mandatory food fortification.