You wrote on the label "Pea microgreens, grown without pesticides, packed 08.03" - and consider that everything is done correctly. But if you sell through a store or at a market, the packaging must also show the producer's name and address, net weight, storage conditions, and best-before date in a clear format - otherwise this is grounds for a fine at the first inspection.
Quick glossary: Labeling - the mandatory set of information on food product packaging as defined by law; the absence of any required element is a violation regardless of whether other elements are present. Best-before date - the date until which the product retains its quality under the stated storage conditions; for greens and microgreens typically expressed as "use by" or "best before" with a specific date. Batch - a unit of product manufactured under the same conditions at the same time; a batch number enables traceability in the event of a complaint or recall.
What Is Mandatory: The Basic List
Mandatory labeling for greens and microgreens in Ukraine covers a specific product name, the producer's name and address, net weight, a best-before or use-by date, storage conditions, and a batch code. Country of origin is required when leaving it out could mislead the buyer.
These requirements come from the Law "On Consumer Information Regarding Food Products" No. 2639-VIII. The wartime labeling relief in place since March 2022 is canceled as of October 1, 2026; products labeled earlier under the old rules may be sold until their date runs out.
Product name - specific: "Sunflower microgreens," not "Microgreens" or "Fresh greens." If the product contains a blend - list the composition.
Producer's name and address - legal name and address, or the sole proprietor's full name and address.
Net weight - in grams or kilograms. "Approximately 100 g" does not meet requirements - the weight must be stated as actual with permissible tolerance.
Production date and best-before date - as "packing date" and "use by DD.MM.YYYY" or "suitable for consumption within X days of packing date." Both formats are acceptable, but the consumption date must be unambiguous.
Storage conditions - temperature range: "store at 36-43°F (2-6°C)." If there are special requirements (e.g., "do not freeze") - state them.
Country of origin - mandatory only when leaving it out could mislead the buyer about where the product comes from. "Ukraine" on the label settles the question.
Batch code - a code preceded by a Latin "L," for example L2409-1; a packaged product without it may not be placed on the market. The batch code lets you trace and recall a specific run after a complaint, and the HACCP system requires it too.
Fines are imposed by the State Food and Consumer Service under Article 65 of Law No. 2042-VIII. Incomplete or inaccurate label information costs a sole proprietor 10 minimum monthly wages (86,470 UAH) and a company 15 (129,705 UAH); noncompliant labeling that poses no health risk costs 3 and 5 (25,941 and 43,235 UAH). The most expensive is omitting an allergen: 20 and 30 minimum wages (172,940 and 259,410 UAH). Amounts as of September 2026.
Which Allergens Must Be Declared on a Microgreens Label
Law No. 2639-VIII lists 14 allergen groups, and any of them present in the product must be named on the label. Several microgreens crops overlap with this list: mustard, celery, wheat, oats, barley, soy, and sesame.
The 14 groups: cereals containing gluten (wheat, rye, barley, oats), crustaceans, eggs, fish, peanuts, soy, milk and lactose, tree nuts (eight species, from almond to macadamia), celery, mustard, sesame, sulfur dioxide and sulfites above 10 mg/kg, lupin, and mollusks.
How to declare them. If the package carries an ingredient list, the allergen is emphasized in it by font, color, or style. If there is no ingredient list, write "contains" before the allergen name. Nothing extra is needed when the product name already clearly refers to it: on "Mustard microgreens" the name itself is the declaration. The trap is blends: in a "Spicy mix," mustard must be emphasized in the ingredient list or the label must add "contains mustard."
What Is Additionally Required for Sales Through Stores and Retail Chains
Retail chains and even small stores typically require more than the law does: an EAN-13 barcode and often nutrition information on the label. The batch code, however, is mandatory by law on every packaged unit, whatever the sales channel.
Barcode (EAN-13) - without it a product cannot be entered into the database of most retail systems. Obtained through GS1 Ukraine.
Nutrition information covers energy, fat, saturated fat, carbohydrates, sugars, protein, and salt. The law does not require it for fresh single-crop microgreens: unprocessed products made of a single ingredient are exempt.
What "Storage Conditions" Means in Practice
Writing "store in refrigerator" is not sufficient. The regulator requires a temperature range. For greens and microgreens the standard is: 36-43°F (2-6°C), relative humidity 90-95%. If the packaging uses modified atmosphere (MAP) - state "do not open until use" or equivalent.
Shelf life under correct storage conditions and a maintained cold chain is 5 to 14 days depending on the crop and packaging method. State a shelf life that genuinely reflects product quality at the end of the period - not the maximum theoretically possible. If a buyer complains "it spoiled before the best-before date" - the producer bears responsibility.
Three Mistakes That Cost the Most
Different labeling for different sales channels. At the market - a handwritten sticker; to a store - proper packaging. If the producer is registered - requirements are identical across all channels. "No one checks at the market" - until the first State Food and Consumer Service inspection.
Best-before date without storage conditions. "Use by 15.03" without stating storage conditions is incomplete labeling. A product that spoiled in three days at the buyer's room temperature becomes your problem if the conditions were not stated.
Not updating labeling when composition or conditions change. Changed substrate, started using a biological fertilizer, changed seed supplier - if the packaging contains any claims about the growing method ("pesticide-free," "organic"), those claims must reflect the actual current situation. Inaccurate labeling is an administrative liability and a reputational risk.
How to Know Labeling Meets Requirements
Take a package and run through the checklist: product name, producer with address, net weight, packing date, best-before date, storage conditions with temperature, a batch code with "L," and for mustard, celery, or wheat in a blend, an emphasized allergen. If any element is missing, the labeling is incomplete.
If you want to go deeper: facility registration for microgreens explains how to register for free before your first sale. Without it, even a flawless label does not make the sale legal.