How to import to Ukraine chemicals that are not controlled by the State Service on Medicines and Drugs?

We help to obtain the conclusion of the State Service of Ukraine on Medicines and Drugs about the absence of controlled substances in imported goods.

Many people ask: “What do I need this document for?” After all, there is an approved List of narcotic drugs, psychotropic substances and precursors. And if a chemical is not on this list, it means that it does not belong to the substances subject to the state control.

But in practice, as in any case, the things are not that simple when you are dealing with a state authority.

This document is often asked at customs to make sure that your substances are not on the List. What’s easier for a customs officer: to check the list or just ask you for the relevant certificate? The answer is obvious.

Today we will talk about the cases when you need such a certificate, and will discuss situations that may arise when importing chemicals to Ukraine.

Related article: What should you know when planning to start working with precursors, psychotropic substances and narcotic drugs?

Which goods require obtaining a conclusion (explanation letter) by the State Service of Ukraine on Medicines and Drugs?

If you plan to import any chemicals to Ukraine, you are already at risk of being asked for this document.

Especially if the substance contains such words as “ethanol”, “propylene”, “phenyl”, “methyl”, such abbreviation as “PEG-200”, and so on.

How to get this document and how long does it take?

In order to receive such an explanation letter, you need to submit a request to the State Service of Ukraine on Medicines and Drugs with a document that explains the full chemical composition of the product. As a rule, it is a manufacturer’s certificate.

We can provide you with a comprehensive information about the procedure for obtaining this certificate during the consultations or prepare all the necessary documents for you.

The State Service on Medicines and Drugs shall respond to your request within one month.

Note! Sometimes it turns out that the goods contain substances subject to control of the State Service on Medicines and Drugs, even if you do not find such a substance in the List.

Related article: What are the common mistakes that may affect the process of obtaining the Precursor License?

How can a chemical come to be subject to control of the State Service on Medicines and Drugs?

The fine print. The List of substances subject to the state control contains the following remarks: “This list shall also include salts of all substances listed here, if the formation of salts is possible”.

Thus, even if the chemical itself is not on the list of controlled substances, but if it turns out that the substance is nothing but salt formed as a result of the interaction of the controlled substance with something, it shall be treated as a substance subject to state control.

Everything depends on the percentage. If the mixture contains, for example, less than 50% acetone, it is not subject to control, but if its content equals to or exceeds 50%, it shall be treated as a controlled substance.

If a mixture contains two substances that are not controlled until a certain percentage is exceeded, but they jointly exceed the allowable percentage of one of them, the mixture shall be subject to control.

For example: acetone shall be subject to control at a concentration 50%, hydrochloric acid - at a concentration 15%. If the mixture contains 20% acetone and 1% hydrochloric acid, it shall be subject to the state control.

Related article: Obtaining A License For Use Of Precursors: Innovations In The Procedure

How to import chemicals that are controlled by the State Service of Ukraine on Medicines And Drugs?

Firstly, you need to obtain the Precursors License, and secondly, you shall obtain a permit to import precursors at the State Service of Ukraine on Medicines and Drugs.

For more information on obtaining the license and the process of importing substances controlled by the State Service of Ukraine on Medicines and Drugs, see our publications in the Useful Information section or contact our specialists.

If you want to import any chemicals to Ukraine legally and without problems - call us!

Publication date: 06/12/2019
Marina Losenko

About author

Name: Marina Losenko

Position: Associate

Education: National Aviation University

Knowledge of languages: Russian, Ukrainian

Email: [email protected]

Marina Losenko is a lawyer of the company, specializing in corporate law and intellectual property law.

Marina has extensive experience of registration and dissolution of enterprises, charities and non-governmental organizations, representative offices of foreign companies as well as formalization of changes to registration information of the entities.

For quite a long time she has been working in the field of licensing and obtained licenses for different types of business activities including sale of medicines (license for activities of drugstores); wholesale of pesticides and agrochemicals; activities with scrap; activities with hazardous wastes; operations with scrap of precious metals and gemstones; private security services; transportation; tour services; use of redio frequency resource; IPTV services, etc.


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