Accessing European Union markets for Ukrainian products requires not only high quality but also continuous adaptation to updated EU legislation. That is why the State Service of Ukraine on Food Safety and Consumer Protection continues to inform market operators about key changes that may affect exports.
The European Union continues to improve its system of veterinary controls for imported products. On 23 July 2026, Commission Delegated Regulation (EU) 2026/1052 was published, amending Delegated Regulation (EU) 2020/692 concerning the entry into the EU of animals, germinal products and products of animal origin from third countries. The Regulation will enter into force 20 days after its publication, i.e. on 12 August 2026.
The document takes into account the experience gained from applying the existing EU legislation, recommendations of the European Food Safety Authority (EFSA), the World Organisation for Animal Health (WOAH), as well as the latest developments in food safety.
For Ukrainian exporters, this means the need to review certain production processes, traceability systems and approaches to preparing documentation for exports to the European Union.
Additional specific conditions for the import of certain commodities
One of the most important innovations is the introduction of additional specific conditions for the import of certain commodities.
From now on, inclusion on the list of countries authorised to export to the EU does not automatically mean that all products from that country are eligible for entry. For certain commodities, the European Commission may require additional testing or additional documents or certificates concerning the origin of the products, animal vaccination status or other evidence of compliance.
Additional conditions may be established not only based on the absence or presence of a specific disease, but also taking into account a broader range of factors, including the country’s animal health status, the effectiveness of its control and surveillance systems, outbreak response capacity and other epidemiological characteristics.
For example, the rules concerning the import of horses have been amended. Specific conditions will apply regardless of the category to which the country or territory belongs if, during the specified period, any of the following diseases has been recorded in its territory:
• African horse sickness;
• Venezuelan equine encephalomyelitis;
• glanders caused by Burkholderia mallei;
• dourine;
• surra caused by Trypanosoma evansi.
The Regulation also introduces a provision under which veterinary rules will no longer apply to the entry into and subsequent movement within the EU of gelatin, collagen and highly refined products of animal origin listed in Section XVI of Annex III to Regulation (EC) No 853/2004, while other EU import control requirements — including hygiene, safety, labelling and contaminant controls — remain applicable.
Stricter requirements for animal traceability and identification
The Regulation updates the rules on the identification of kept ungulates, equine animals, ratites, ornamental birds and pet birds.
For most animal species, identification must be carried out using electronic transponders or tags in accordance with international ISO standards. If an electronic identifier does not comply with international standards, the importer must ensure that it can be read.
For ungulates, before departure from the establishment and in accordance with international ISO standards (the identification code must contain the ISO 3166 country code and a unique animal number):
• for all species other than equine animals — an ear tag or electronic tag must be used, with the visual and electronic codes matching;
• for equine animals — an injectable transponder, conventional ear tag, electronic tag or identification document must be used.

Where the horse is not intended for slaughter, the identification document must contain a description of the animal, its individual characteristics and transponder data;
• for ungulates destined for confined establishments (zoos, scientific institutions and rehabilitation centres) — alternative identification rules may apply;
• if an electronic identifier does not comply with ISO 11784 and ISO 11785, the importer must ensure that a device capable of reading it is available. At the request of a third country, the European Commission may agree to the use of a different code instead of the ISO 3166-1 code.
For ratites, before departure from the establishment and in accordance with international ISO standards (the identification code must contain the ISO 3166 country code and a unique animal number), a leg band or an injectable transponder must be used. If the identifier does not comply with ISO 11784 and ISO 11785, the importer must ensure that a device capable of reading it is available.
For ornamental and pet birds, before departure from the establishment, a leg ring or injectable transponder must be used, containing a unique numerical code and the country code of the country in which the bird was first identified. Exceptions are also provided for cases where the bird is sent to a confined establishment, was previously identified according to another internationally recognised standard, there is no doubt about its original identification, and there is an unequivocal link between the bird and the veterinary certificate.
These changes are aimed at improving the traceability of animal origin and increasing transparency in international trade.
New requirements for meat product manufacturers
Stricter controls on the origin of raw materials are being introduced for meat products.
If the country of origin of the raw material is not authorised to export fresh meat to the EU without specific conditions, the raw material must undergo the treatment regime established by the European Union for the relevant country or zone of origin of the products and raw materials. The treatment must be sufficient to reduce the risk of disease spread.
Updated rules for dairy products
The Regulation revises the requirements for the production of dairy products depending on the type of milk and the method of processing. If a product is manufactured from a mixture of milk from different animal species, the strictest processing requirements will apply.
In particular:
• dairy products manufactured both from raw milk and from other dairy products that were previously manufactured from raw milk may enter the EU under the general processing rules applicable to products of animal origin;
• two main categories of dairy products are distinguished in the context of processing: Category A — milk from cattle, sheep, goats, buffaloes and dromedary camels; and Category B — milk from all other species, to which stricter rules apply;
• rules are established for processing products made from different types of milk: if processing takes place before mixing, each type of milk must be processed separately according to the applicable requirements; if processing takes place after mixing, the strictest treatment regime applicable to any of the animal species whose milk is included in the mixture must be applied.
Updated rules for egg products
New conditions have also been established for the import of egg products. They must originate from countries or zones where surveillance programmes for highly pathogenic avian influenza are in place, and the products must undergo treatment specified by the EU against highly pathogenic avian influenza and Newcastle disease.
New rules for manufacturers of composite products
Some of the most significant changes concern composite products containing ingredients of animal origin.
When assessing dairy ingredients, consideration will be given not only to the country where the final product is manufactured, but also to:
• the country of origin of the dairy ingredients;
• the country of origin of the egg ingredients;

the place where they were processed;
• the animal health status of all countries involved in the production chain.
The higher the veterinary risk associated with the country of origin of the ingredients, the stricter the processing requirements will be.
Requirements for egg ingredients have also been established that are similar to those applicable to products made from eggs.
For certain shelf-stable composite products, a simplification has been introduced: instead of a veterinary certificate, a private attestation by the market operator may be used, provided that the established requirements are met.
What Ukrainian exporters should do now
In light of the new requirements entering into force, market operators exporting products to the European Union are advised to:
• analyse whether the new requirements apply to their products;
• verify whether their systems for tracing the origin of raw materials and ingredients comply with the new rules;
• assess whether animal identification systems comply with international standards;
• review production processes for meat, dairy, egg and composite products;
• update internal control procedures and documentation where necessary;
• agree in advance with the territorial body of the State Service of Ukraine on Food Safety and Consumer Protection on the procedure for issuing veterinary certificates and accompanying documents.
The State Service of Ukraine on Food Safety and Consumer Protection continues to monitor changes in European Union legislation and will keep Ukrainian producers and exporters informed about new requirements aimed at facilitating uninterrupted access of Ukrainian products to the European market.
The full text of Commission Delegated Regulation (EU) 2026/1052 of 12 May 2026 is available on the official web portal of the European Union.