"I'm starting to sell microgreens — do I need a licence?" Or the opposite: "I'm an individual, selling at a market — nothing required." Both statements are wrong. A food production licence as such does not exist in Ukraine — there are facilities subject to state registration, operators who must notify authorities of their activity, and food safety requirements that apply depending on scale and sales channel. Where you sit in this framework determines exactly what you need to do.
Quick Glossary
- Food business operator — any natural or legal person who produces, processes, or sells food products; subject to the Law of Ukraine "On Basic Principles and Requirements for the Safety and Quality of Food Products"
- Facility registration — a mandatory procedure for enterprises producing food products in certain categories; carried out through the State Food and Consumer Service (Derzhprodspozhyvsluzhba)
- HACCP — Hazard Analysis and Critical Control Points; mandatory for food business operators not exempt under the micro-enterprise exception
Who Must Do What: Three Levels
Ukrainian legislation (Law No. 771/97-VR as amended, harmonised with EU Regulation 852/2004) sets requirements based on scale:
Level 1 — Micro-producer (individual or sole trader) selling directly to the consumer at a market. For direct sales to the end consumer (farmers' market, on-farm, via social media to a private individual) — a more flexible approach is permitted. Facility registration is not always mandatory, but hygiene rules and minimum product safety requirements apply. Core requirement: the product must not pose a risk to the consumer.
Level 2 — Sole trader or legal entity supplying to businesses or shops. When supplying to restaurants, shops, schools, hospitals, or any intermediary — facility registration with the State Food and Consumer Service is mandatory, or notification of activity is required (depending on product category and scale). HACCP requirements are mandatory.
Level 3 — Enterprise supplying retail chains or exporting. Full registration, HACCP, inspection by the State Food and Consumer Service. EAN barcode, labelling meeting all applicable requirements.
Registration or Notification Procedure
Notification of commencement of activity — a simplified form for operators who do not require full registration. Submitted to the regional State Food and Consumer Service office. The document confirms that you have declared your production activity and accept responsibility for product safety. It is not a permit — it is a declaration.
Facility registration — for enterprises subject to mandatory registration. Includes: an application, description of facilities (production premises, equipment), a HACCP plan or description of the food safety management system. The State Food and Consumer Service may conduct an inspection before issuing the registration document.
What to prepare regardless of level:
- Description of the production process (what is produced, how, and where)
- Risk identification (minimum: who could be harmed by the product and how)
- A basic batch traceability system linked to production records
- Storage and transport conditions for the finished product
Labelling Requirements for Legal Sales
Regardless of registration level — packaged products must be labelled. Minimum requirements:
- Product name
- Producer or seller with address or contact details
- Date of manufacture and best-before date
- Storage conditions
- Net weight
For retail chain supply — additionally: EAN-13 barcode, nutritional information (macros and calories), allergen warnings where applicable.
Organic Certification: Separate from Registration
Food producer registration and organic certification are two separate, independent procedures. Registration is mandatory when supplying to trade — organic certification is voluntary but required to use the label "organic" or "органічний."
Organic certification in Ukraine is issued by accredited certification bodies (under the Law of Ukraine "On Basic Principles and Requirements for Organic Production"). Transition period: 2 years for plant products before initial certification. Requirements include: no synthetic pesticides or fertilisers, documentation, and annual audit.
Three Mistakes That Cost the Most
Assuming "sole trader on simplified tax = nothing required" when supplying shops or restaurants. Sole trader status is a tax regime, not an exemption from food safety obligations. Supplying to legal entities under any form of business requires compliance with product safety requirements and corresponding documentation.
Delaying registration until "we grow bigger" and supplying retail or restaurants without documentation. The first inspection or customer complaint — and the absence of registration for commercial supplies is a violation. It is far simpler to complete the procedure before deliveries begin than during an incident.
Confusing facility registration with product approval. Registering a facility does not mean a specific product is "approved" — the safety of each batch is the operator's responsibility. HACCP and production documentation are the tools that demonstrate the operator manages food safety systematically, not on an ad-hoc basis.
How to Know You Are Operating Legally
- You understand your level (direct consumer sales vs. supply to businesses)
- When supplying to businesses or shops — registration or notification with the State Food and Consumer Service is in place
- Each product batch is identified and traceable
- Labelling meets the minimum requirements for your sales level