As of January 1, 2025, the State Environmental Inspectorate of Ukraine has resumed scheduled inspections of the quality of motor gasoline, diesel, marine, and boiler fuel. These market surveillance inspections were temporarily suspended during martial law but have now been reinstated following Resolution No. 1511 of the Cabinet of Ministers of Ukraine, adopted on December 27, 2024.
It is worth noting that unscheduled environmental inspections had already resumed in the summer of 2024 due to amendments introduced by Government Resolution No. 261 on March 8, 2024, to Resolution No. 303, titled “On the Suspension of State Supervision (Control) and State Market Surveillance Measures During Martial Law.”
Additionally, on December 24, 2024, the Law of Ukraine “On Minimum Reserves of Oil and Petroleum Products” came into effect. This law introduced amendments to the Law of Ukraine “On Consumer Rights Protection” regarding the retail trade of petroleum products and supplemented the second part of Article 15 with the following provisions:
Retail fuel businesses are required to display information on:
• Fuel designation (name, brand, type, and bio-component content) on fuel dispensing equipment, at the consumer information corner, on an information stand in the checkout area, and—if technically feasible—on information boards installed at the entrance to gas stations, autogas stations, and autogas points.
• Fuel designation (name, brand, type, octane rating, environmental class, additive (admixture) content, and bio-components), copies of fuel quality documents (quality passports), and copies of conformity declarations—near the station operator or in locations accessible to consumers at gas stations, autogas stations, and autogas points.
As a result, many fuel retailers are now required by inspectors to provide a conformity declaration proving that imported fuel meets Ukrainian standards.
The Fuel and Energy Business Association has examined the challenges of proving compliance for both imported and domestic fuel under the Technical Regulation on the Requirements for Motor Gasoline, Diesel, Marine, and Boiler Fuel, approved by Resolution No. 927 of the Cabinet of Ministers of Ukraine on August 1, 2013, within the conditions of martial law.
Simplified Control for Imported Fuel
During martial law, the Ukrainian government introduced simplifications for fuel imports. Under Cabinet of Ministers Resolution No. 555 of May 10, 2022, fuel imports from EU countries were allowed without mandatory conformity assessment under Ukrainian standards.
This resolution amended paragraph 5, second subparagraph, of the Technical Regulation on Fuel Requirements (approved by Cabinet Resolution No. 927, August 1, 2013), now stating:
“It is permitted to manufacture, place on the market, and trade fuels that comply with this Technical Regulation.
It is also permitted to place on the market and trade fuels imported into Ukraine from EU member states and other countries (except for fuel originating from the Russian Federation and the Republic of Belarus or fuel owned by legal entities registered in these countries, or where the ultimate beneficiaries are Russian or Belarusian entities or individuals subject to sanctions under the Law of Ukraine ‘On Sanctions’).
This is based on a document issued by a foreign economic operator or conformity assessment body confirming that the fuel meets this Technical Regulation. The document, issued in its original language, must verify compliance with EN 228 (motor gasoline) and EN 590 (diesel fuel) or their equivalents.
This simplification remains in effect until the end of martial law and for an additional 90 calendar days after its cancellation.
Fuel confirmed by such a document may be sold to end consumers in Ukraine until the end of martial law and for an additional 90 calendar days thereafter.”
Thus, imported fuel can be placed on the Ukrainian market based on a compliance document issued by a foreign economic operator or conformity assessment body, verifying compliance with European standards:
• EN 228 – for motor gasoline
• EN 590 – for diesel fuel
These simplifications will remain in force until the end of martial law and for an additional 90 calendar days.
What to Do If Compliance Documents Are Requested During an Inspection?
If inspectors request a conformity declaration, but you have a foreign certificate of conformity or another original document issued by a foreign economic operator or conformity assessment body confirming compliance with European standards, follow these steps:
1. Refer to the temporary regulations.
2. Provide the certificate or another conformity document in its original language, verifying compliance with EN 228 or EN 590.
3. Quality passport: Present the quality passport for each batch of fuel, which must accompany the product throughout its distribution chain. The quality passport includes test results for a specific fuel batch.
4. If needed, provide explanations: If inspectors insist on a conformity declaration, argue that the foreign compliance document is recognized as equivalent during martial law.
Compliance Assessment for Domestic Fuel
Unlike imported fuel, domestically produced fuel must undergo a mandatory conformity assessment per the Technical Regulation approved by Cabinet Resolution No. 927 (August 1, 2013).
The conformity assessment procedure includes:
1. Sample testing – Conducted by accredited laboratories to determine key quality and safety indicators.
2. Issuance of a quality passport – Confirms that a specific fuel batch meets established requirements.
3. Declaration of conformity – Issued by the manufacturer after obtaining positive test results.
These documents are mandatory for introducing domestic fuel into circulation and must be presented during regulatory inspections.
Key Takeaways for Fuel Market Operators
1. Imported fuel is temporarily exempt from mandatory Ukrainian conformity assessment, simplifying import and sales procedures.
2. Domestic fuel must undergo full conformity assessment before being introduced into the market.
3. Once martial law ends, conformity assessment will become mandatory for all fuels, regardless of their country of origin.
These regulations aim to ensure fuel quality in the Ukrainian market and protect consumer rights.
Alina Potapovych. Head of the Legal Affairs and Legislative Committee