The standards have been updated—and these aren’t just cosmetic changes
In January, the Ministry of Economy released an updated list of harmonized standards. In short: many of the standards referenced in your declarations of conformity now have new versions. The old ones are still in effect for now—there is a transition period. But “still in effect” and “in effect forever” are two different things.
Home appliance manufacturers have been hit the hardest. The DSTU EN IEC 60335-1 standard—the “parent” safety standard covering everything from irons to multicookers—has been updated. And it’s not just a matter of renumbering the sections. Requirements for software have been added. So if your water heater has a microcontroller board (and almost all of them do these days)—it’s now considered a software-based product, and the requirements are different. We learned this the hard way when the lab returned the client’s samples with the comment “additional testing is required.” It wasn’t pleasant, but it’s better to find out now than during an inspection.
They also updated DSTU EN 62368—this covers computer equipment, monitors, and audio systems. I advise electronics importers not to ignore this—the new version significantly changes the approach to classifying energy sources within a device.
What should you do about this? Open your test reports and declarations and check the standard number. Then visit the UkrNDNC website and see if there is a replacement standard. If there is, find out the end date of the transition period and schedule new tests in advance, because laboratories are swamped with orders during the pre-transition period and the backlogs are growing. Allow at least a month to a month and a half for the full product certification cycle under the updated standard.
Sanitary certificates: good news for importers
To be honest, this is the best thing that’s happened this quarter. Starting in February, the procedure for issuing sanitary and epidemiological certificates has changed. Two changes. The first is that cleaning products, cosmetics, and some building materials can now be processed electronically, without having to visit the local authority. Anyone who used to haul folders back and forth will understand how much this makes life easier.
The second change is more interesting. They’ve finally established a proper procedure for recognizing foreign test reports. Previously, this was theoretically possible, but in practice, each inspector decided on their own, and most often decided, “No, let’s use ours.” Now, if a supplier has reports from an ILAC-accredited laboratory, there is an official basis for accepting them without retesting in Ukraine.
We’ve already tested this on two projects. In one case, the client-importer saved three weeks and about forty thousand on lab costs—the reports from the German manufacturer fully covered our list of parameters, and the inspector accepted them without question. In the other case, it didn’t work because the reports from the Turkish manufacturer didn’t cover all the required parameters; specifically, there was no microbiology testing using methods acceptable for the Ukrainian market. In other words, there’s no magic wand, but the tool works. Gather the reports from the foreign manufacturer and bring them to us—we’ll tell you right away whether they’re suitable or not.
ISO 9001 and bids: A “Recommendation” you can’t ignore
The Ministry of Economy has “recommended” that government procurement clients require ISO 9001 certification from suppliers of medical products, building materials, and electrical equipment. Anyone who has worked with tenders knows the value of such recommendations—within a couple of months, this effectively becomes a mandatory requirement in procurement documentation. We are already seeing the first tenders with this requirement.
Implementing a management system and obtaining certification takes four to five months—not three, as some “consulting firms” promise. That’s because the system needs to be fully operational for at least three months before the audit, and the internal audit must be conducted properly, not just for show. If you want to participate in tenders in the second half of the year, get started right now; by April, it will be too late.
And a special note for those who already have ISO 9001: when is your surveillance audit? We had a case where a company spent a month preparing for a tender, put together the entire bid package, and met the price requirements, only to find out that their certificate had expired two weeks earlier. They were rejected. Check the expiration dates—it takes five minutes, but the consequences are incalculable. If your certificate is set to expire in the coming months, don’t delay in renewing your management system, because a surveillance audit also requires preparation.
Transition periods that have ended
Toys. For those who have been putting off the transition to the updated safety regulations—that’s it, time’s up. The permissible levels of phthalates and bisphenol A have been lowered, and mandatory electronic registration of declarations of conformity has been introduced. Two importers came to us in February, thinking “there was still time.” There was no time. Now they’re waiting for a re-evaluation, and the shipment is sitting in the warehouse. It will take at least three weeks, even on an expedited basis—the lab simply cannot physically conduct chemical testing for the entire list of parameters any faster.
CE Marking. Starting March 1, the declaration for CE-marked products must include a unique product or batch identifier. Previously, a general description such as “household electronic scales” was sufficient. Now, more specific details are required—the model, part number, or batch serial number. It might seem like a minor detail—but in early March, one of our clients had a shipment held up at customs precisely because of this.
The products fully met safety requirements, the test reports are up to date, everything is perfect—but the declaration is missing the identification number. And that’s it—hold up, customs won’t let it through. Check your declarations; this can be fixed quickly—but it’s better to do it before shipment, not when the cargo is stuck at the border.
Building materials. Thermal insulation and floor covering mixtures—now only in accordance with DSTU EN. Test reports based on the old standards are no longer accepted for the issuance of certificates and declarations. I know of cases where manufacturers submitted documents with test reports based on DSTU B as early as January—they were rejected. Retesting according to DSTU EN is not much more expensive, but it takes time to find a laboratory with the appropriate accreditation.
A subtle but insidious change regarding the technical specifications
Most people missed this news because it’s not about a specific product, but about a principle. The State Consumer Standards Service has clarified: your technical specifications cannot set requirements that are lower than those in the relevant technical regulation. It sounds like “well, obviously.” But in practice, many companies operate under technical specifications written seven to ten years ago, when no harmonized regulations existed yet. No one has repealed these technical specifications; they are formally still in effect. But their content may contradict the regulations.
An inspector might now ask, “Prove that your technical specifications do not conflict with the regulations.” If you can’t prove it, you’ll get a corrective order. And this isn’t just theory: one of our clients, a manufacturer of construction mixtures, received exactly this kind of notice in February. The advice is simple: take your technical specifications, place the text of the regulations next to them, and compare the requirements point by point. If something doesn’t match—it’s better to update them yourself now than to wait for the State Service of Ukraine for Food Safety and Consumer Protection to do it for you in the form of an inspection report.
What’s Next: Dates for the second quarter
June 30 marks the end of the transition period for DSTU EN 60335. Household appliances that comply with the old standards will no longer be considered compliant after this date. If you have such products, be sure to schedule testing by May at the latest; otherwise, you will not have enough time to file the declaration.
July 1 is a strict deadline for the electrical engineering sector: all declarations must reference the current versions of standards. Not the repealed ones, not the “we’re still in the transition period” ones, but the current ones.
This fall, a pilot program for an electronic declaration registry is promised. If it works, inspectors will be able to check the status of your declaration online, without any paperwork. For legitimate manufacturers who keep their documentation in order, this is actually convenient—there will be no need to copy and send declarations to partners and inspectors every time. For those who have been operating without documentation—it’s the end of an era.
If any of the points mentioned above apply to your products and you’re not sure whether your documentation is in order—don’t guess; check it. At “Standards and Quality,” we can audit your documentation in just one or two days: we verify the validity of standards, the expiration dates of certificates and reports, and the compliance of technical specifications with regulations. Better to do it today than a month from now.
