Suzana Grigorenko
The topic of GMOs in the Ukrainian agricultural sector has been an uncomfortable one for years. Formally, there was no registered GM organism in the country. In fact, GMO products are on the market, in feed, and in supply chains. The state did not have a complete picture: what exactly was being used, where it came from, and who was responsible for it.
Main points
- The Law on State Control over the Circulation of GMOs in Ukraine will come into force in September 2026, introducing a mandatory GMO register for transparency and accountability in the market.
- The law provides for fines for violating the rules for placing GMOs, ranging from 60.5 thousand to 173 thousand hryvnias, with the possibility of further sanctions for repeated violations.
Suzana Grigorenko
The topic of GMOs in the Ukrainian agricultural sector has been an uncomfortable one for years. Formally, there was no registered GM organism in the country. In fact, GMO products are on the market, in feed, and in supply chains. The state did not have a complete picture: what exactly was being used, where it came from, and who was responsible for it.
From September 2026, this “gray zone” will disappear – the law of August 23, 2023 No. 3339-IX on state control over the circulation of GMOs will come into force. Read more in the exclusive column for Channel 24.
There are several strong arguments behind this decision. First, European integration – the EU has some of the strictest requirements for GMO regulation in the world, and Ukraine is obliged to harmonize its legislation. Second, without transparent control, Ukrainian agricultural products will always be under question from international partners. Third, the internal market needs clear rules, and the state is finally getting the tools to provide them.
What the law calls GMOs
The law does not regulate all biotechnology, but only those organisms that, by definition and characteristics, belong to GMOs in the “classical sense.” That is, we are talking about organisms whose genetic material has been altered in ways that do not occur naturally.
The law covers both GM organisms themselves and their sources – feeds, varieties, etc., as well as products produced using them. The law covers work in both open systems (i.e. in the field) and closed systems (laboratories, greenhouses).
It is important to understand: a farmer who buys seeds or feed does not always worry about whether they contain legal GMOs. However, it is the farmer who is responsible for the final product he grows. Therefore, it is worth finding out whether the legal seeds have a legitimate status (registered variety). The new law obliges to check the legal status of what is used in production and to work only with what is included in the register and officially permitted.
State Register of GMOs – how the accounting system will work
All GM organisms officially permitted for use in Ukraine must be entered into the State Register of GMOs. It is the register that determines what is legal in Ukraine and what is not.
The following are entered into the register:
- the name of the GMO and its source,
- a unique number in accordance with OECD international standards,
- owner information,
- characteristics of the organism (including genes, traits, and method of genetic transformation),
- purpose of use and detection method,
- monitoring plan after registration (because registration is not a one-time action, but the beginning of tracking).
The owner of a GMO registers it, not the farmer. But the farmer is responsible for working only with what is included in the register. The register is public, so the argument “I didn't know” no longer works – the farmer must take care of this himself and check with the manufacturer whether the seeds or feed contain legal GMOs.
In addition to the GMO register, the law provides for two more: a register of subjects of genetic engineering activity and a register of permits for research and testing in an open system. Together, they form a complete picture of who uses what, and where.
What's changing for manufacturers
For farmers, the new law is primarily certainty. For the seed market, it means real responsibility at every stage of the chain. The owner of the GMO registers the organism and receives permission. The agricultural producer checks the legal status of what he buys and, if necessary, is included in the List of GMO Producers – an open register containing information about who grows what, where and where.
As for those who will look for loopholes – the law leaves no room for interpretation. Responsibility is specific and financially tangible. For violating the rules for placing GMOs on the market, a legal entity receives a fine of 15 to 20 minimum wages (from almost 130 thousand to 173 thousand hryvnias) , an individual entrepreneur – from 7 to 10 (from 60.5 thousand to 86.4 thousand hryvnias). Also, the violator is subject to enhanced inspections, possible seizure or destruction of products, and cancellation of permits.
If the violation is repeated within a year, the sanction increases significantly. For those who illegally placed GMOs on the market, the fine will be 100% of the cost of the entire batch of such products, but not less than 100 thousand hryvnias. For violations in other areas, the fine will be double the base fine.
That is, in both cases, a repeated violation is a real threat to the business, not just an unpleasant but acceptable expense.
Farms that previously worked with GMOs without proper registration have time to adapt, but it is limited – there are only a few months left.
Plus for export
Ukrainian agricultural products are traded in markets where requirements for biosafety and supply chain transparency are constantly increasing. And every time a partner cannot get a clear answer to a question about the GMO control system, it is a potential risk to the deal.
The new law eliminates this risk or at least significantly reduces it. A state register of GMOs, an open list of producers, documented registration and monitoring procedures are all elements of a system that can be shown to a partner and referenced.
And one more point: upon accession to the EU, the registration of GMOs not permitted in the European Union will be automatically canceled. This is built-in harmonization, which eliminates potential trade conflicts before they arise.
In the end
It is significant that the law does not try to resolve the issue of “GMOs – good or bad”. It resolves something else: how to ensure that all market participants play by the same rules and are responsible for their actions. In particular, when buying seeds or other products, an agrarian must check in the State Register whether such a variety exists and whether they contain legal GMOs. This is the basis of a mature regulatory system , where everyone chooses their own strategy, but can no longer pretend that the rules do not exist.
For Ukraine, which seeks integration into the European space, this is also a signal of maturity and the ability to regulate complex issues without populism.
The column is the author's personal opinion; the editorial staff of Channel 24 may not share it.