he business community, through the combined efforts of the Union of Ukrainian Entrepreneurs, European Business Association, and American Chamber of Commerce in Ukraine, appeals once again to the Verkhovna Rada’s Chairman Dmytro Razumkov and parliamentary factions concerning the critical situation that developed in the animal feed market.
More specifically, the business urges the parliament to support the finalized Draft Law No. 3672 “On Animal Feed Safety and Hygiene” as a temporary response to help unblock the market of feeds for domestic animals.
As a reminder, on 19 January 2020, the Law of Ukraine No. 2264-VIII “On Animal Feed Safety and Hygiene” took effect to regulate, among other things, production and imports of feeds, in particular, those for domestic animals. The Law has abolished the registration system previously used for prepared animal feeds and introduced instead some new requirements allowing prepared feeds to be produced in or imported to Ukraine only if feed additives they contain are listed in the State Register of Feed Additives.
Starting from January 2020, the now-defunct state registration of prepared animal feeds has stopped working to be replaced according to the new rules by the registration of feed additives contained in prepared animal feeds. However, the new system was not launched at the same time and has not been launched ever since. On top of this, despite the two-year transition period stipulated by the Law, it has not been yet determined whether the EU requirements applicable to registration of feed additives may be recognized as equivalent to the Ukrainian regulation requirements, which constitutes the condition for introducing the simplified procedure for state registration of feed additives in Ukraine.
This all means, only the feeds registered before 2020 may actually sell on the today’s domestic market, while imports and production of feeds with new or improved formulas are indefinitely suspended.
As of today, this critical situation has already resulted in the reduced supplies available at the feed market, and unless resolved soon enough, it may in the longer run pose a risk of a complete disruption in the country’s circulation of animal feeds containing feed additives.
What the draft Law No. 3672 basically offers is to establish an additional transition period for specific provisions of the Law and this way defer the application of the requirement to produce or import only the animal feeds that contain feed additives listed in the State Register of Feed Additives. As expected, provisions of the Law will be fully implemented and the new state registration system for feed additives will be put in place for practical use within this transition period granted by the Draft Law No. 3672.
Well aware of the crisis developments in the animal feed market, the Verkhovna Rada’s Committee on Agrarian and Land Policy supported the business community’s suggestions and, at its meeting on 30 September 2020, recommended the Ukrainian Parliament to pass the Draft Law No. 3672 as a basis and as a whole.
In view of the above, the business community calls on parliamentary factions and deputies to address this situation. We request the leadership of the Verkhovna Rada of Ukraine to include the Draft Law No. 3672 in the agenda of the Verkhovna Rada’s plenary meetings scheduled for 3 to 6 November 2020, and we request people’s deputies to support and pass this draft law as a basis and as a whole.
