The Ukraine Refusal Letter is an official assessment letter that helps explain whether a product is additionally subject to a conformity document under the relevant technical regulations for its placing on the market, import or a specific intended use in Ukraine.
Referred to on the market as the “Ukraine Refusal Letter”, “Ukraine Letter of Non-Requirement”, “Letter of Refusal” or by similar terms, this document can be used, particularly where the product is not subject to a mandatory conformity assessment, to explain the product's status under current legislation to the parties concerned.
Today, however, product conformity in Ukraine is addressed not through the old UkrSEPRO system, but within the framework of the technical regulations the product falls under and the relevant conformity assessment procedures. Ukraine's technical regulation system has been developed in line with harmonisation work with European Union legislation.
What Is the Ukraine Refusal Letter Used For?
Before a product is offered on the Ukrainian market, matters such as the following need to be assessed:
- Which technical regulations the product is subject to,
- Whether a mandatory conformity assessment is required,
- Whether a declaration or certificate of conformity is required,
- Whether the product falls under a specific technical regulation
If the regulatory review finds that a specific conformity document is not required for the product, a Refusal Letter / Letter of Non-Requirement explaining this situation can be prepared in line with the intended use concerned.
In Ukrainian legislation, the basic legal framework for technical regulations and conformity assessment procedures was created by the law “On Technical Regulations and Conformity Assessment”.
In Which Cases Can the Ukraine Refusal Letter Be Used?
The need for a refusal letter may vary according to the nature and intended use of the product.
For example, the relevant technical regulations can be examined to determine whether the product is subject to conformity assessment for:
- Industrial products,
- Machinery and equipment,
- Spare parts,
- Electrical and electronic products,
- Consumer products,
- Packaging and auxiliary products,
- Certain technical equipment
Important: Whether a product can obtain a Refusal Letter should not be stated definitively by looking only at the product name or HS code. The product's technical characteristics, intended use, operating principle, user profile and the relevant technical regulations to be applied in Ukraine must be assessed together.
Refusal Letter for Customs Procedures
Letters referred to in practice as a “Refusal Letter for customs” can be used to help explain the relevant conformity requirements when the product is imported into Ukraine.
Such a letter may generally contain information such as:
- Importer,
- Manufacturer,
- Product name,
- Model or product group,
- Technical characteristics,
- HS code,
- Intended use of the product,
- Relevant technical regulation and conformity assessment status
However, the Refusal Letter should not be thought of as a permit that replaces the customs authorities in every case. The request of the customs or market surveillance authorities must be assessed separately according to the nature of the product and the applicable legislation.
Refusal Letter for Sale and Placing on the Market
In assessments relating to the sale or placing on the market of the product in Ukraine, the technical regulations the product is subject to are examined and the required conformity procedure is determined.
The basic approach in Ukraine's current system is to determine whether the product meets the requirements of the relevant technical regulation and, where necessary, to carry out a conformity assessment.
For this reason, instead of using a general statement such as “the product can be sold without a certificate”, carrying out a product-based regulatory assessment is more accurate and safer.
Information Required for the Ukraine Refusal Letter
So that we can carry out a preliminary assessment, we recommend sharing as much of the following information as possible:
- Product name and product group
- Product model
- Technical characteristics
- Intended use
- Manufacturer's details
- HS code
- Existing CE certificates or test reports
- Technical file or product catalogue
- Details of the importer in Ukraine
- Intended use of the document: customs, sale, tender or another transaction
On the basis of this information, the product can be assessed under the current technical regulations in Ukraine and the required conformity procedure can be determined.
Current Conformity Assessment in Ukraine
In Ukraine's current quality infrastructure, the technical regulation, conformity assessment and accreditation system is run in line with Ukraine's relevant legislation and the harmonisation work with the European Union.
For this reason, the old UkrSEPRO obligation should not be regarded today as a certificate system that must automatically be applied to all products.
At Istanbul Certificate Office, we provide consultancy to companies wishing to export to Ukraine on product-based regulatory and conformity assessment, determining the type of document required and coordinating the relevant certification process.
Have Your Product Checked Before Exporting to Ukraine
To determine whether a Refusal Letter is required for your product, or whether a different conformity assessment will be carried out instead, you can send us your product information.
By carrying out a preliminary assessment on the basis of product name + HS code + technical characteristics + existing documents, we determine the route to be followed for entry into the Ukrainian market.
Istanbul Certificate Office
Ukraine Certification and Conformity Assessment Services
