AEMPS Certificate Apostille for Ukraine: Spanish CLV, CEX and CPP Guide

Ginkgo Advisory · AEMPS export document review and legalisation coordination

Using an AEMPS certificate in Ukraine: the key points

Before using an AEMPS certificate in Ukraine, check its intended purpose, the products it covers and whether it already includes a valid Spanish e-Apostille. For public documents that require authentication and fall within the Apostille Convention as it applies between Spain and Ukraine, an apostille can generally replace consular legalisation. Ginkgo Advisory can review CLV, CEX and CPP certificates, verify electronic documents and coordinate any further authentication and delivery required.

AEMPS stands for Agencia Española de Medicamentos y Productos Sanitarios. Document authentication concerns the signature, the capacity in which the signatory acted and the origin of the seal or stamp. Product quality, registration, import licensing and market access remain subject to the relevant regulatory procedures.

Which local requirements should you check before exporting to Ukraine?

Official regulatory enquiries: Ukrainian medicines regulator (formerly DLS; transitioning to the Ukrainian medicines agency). The regulator is undergoing an organisational transition. For specialist pharmaceutical review, also check the current responsibilities of the Ministry of Health and State Expert Centre.

1. Ukraine is restructuring its medicines regulator. Official information published in 2026 describes the former DLS\’s renaming and subsequent transfer of functions. Check the current receiving department, system and forms when submitting, avoiding misdirected documents based on an old authority name.
2. The State Expert Centre\’s pharmaceutical assessment remit does not mean it handles all devices or cosmetics. Prepare AEMPS CPPs, device CLVs and cosmetics certificates according to the product category and receiving authority.
3. Preserve consistent product, manufacturer and authorisation-holder identities across the certificate, translation and annexes. If the organisational transition produces a new request for documents, use the written notice to assess whether further verification or a new certificate is needed. Do not alter a signed PDF yourself.

For these local requirements, see the Ukrainian medicines regulator\’s official website, Ukraine\’s Ministry of Health information on establishing the new agency and State Expert Centre information centre.

Choose the right certificate: CLV, CEX and CPP serve different purposes

For the different document categories, see the AEMPS guidance on medical device certificates, cosmetics CLV guidance and scope of the CPP procedure. Similar certificate names do not mean they certify the same facts.

Since February 2025, AEMPS has provided automatic apostilles for the CLV/CEX certificates covered by its announcement. When you receive a certificate, inspect the files actually downloaded before assuming that a further paid authentication procedure is needed.

CPP system status: As at 30 October 2026, the public AEMPS CPP system page displayed a notice that its apostille function was temporarily suspended, with no definite date for resumption. For pharmaceutical applications, check the system status when submitting and establish the next steps separately for any certificate issued without an apostille.

Which authentication route applies to AEMPS certificates for Ukraine?

According to the HCCH Convention status table checked on 30 October 2026, the Apostille Convention applies between Ukraine and Spain. Whether authentication is needed, whether the document falls within the Convention and whether its contents meet the recipient\’s requirements are separate questions.

1. The certificate already has a valid e-Apostille: Check that the apostille relates to the correct certificate and keep the complete files and verification details. Where the Convention applies, additional consular legalisation is generally unnecessary.
2. The electronic AEMPS document has no apostille: Consider the Spanish justice authorities\’ electronic apostille procedure. Use the route appropriate to AEMPS documents and follow the competent authority\’s requirements.
3. Older certificates, documents with handwritten signatures or unusual documents: Assess reissue, renewal or another appropriate procedure according to the signature format and the recipient\’s checklist. An ordinary scan is not automatically an original that can be authenticated directly.

The Spanish Ministry of Health\’s guidance on electronic AEMPS documents distinguishes documents that already have an e-Apostille from those still awaiting authentication. Documents eligible for the direct electronic procedure do not need a separate, repeated Ministry of Health signature-verification step simply to obtain an apostille.

How do you verify electronic AEMPS documents for Ukraine?

1. Keep the original PDF issued or downloaded from AEMPS, together with every annex, signature and verification-code detail.
2. Use the official AEMPS document verification service, entering the localizador or CSV shown on the certificate and following the system instructions. Do not alter the code or certificate contents.
3. Compare the certificate number, issue date, company details and products with the official record. Record verification of the AEMPS document separately from verification of its apostille.
4. If an apostille is already attached, separately check its issuing authority, number and corresponding document, and retain the complete verifiable authentication file.
5. Give the recipient the correct original files and an explanation of what they contain. Confirm upload, translation or paper-delivery formats before preparing supporting versions.

Under the HCCH guidance on e-Apostilles, where the Convention applies, a valid e-Apostille cannot be rejected solely because it is electronic. Upload procedures, translations, certificate contents and product eligibility are separate requirements that must still be met.

Preparing paper copies, translations and supporting documents

Electronic AEMPS documents can be printed and checked using their verification codes, but an ordinary printout does not create a new paper apostille. If the recipient says that paper documents are required, establish whether they mean a printout for filing, a certified copy, a paper original or another specified format.

For translations for Ukraine, first confirm the required language, whether the authentication pages and annexes must also be translated, and any requirements for the translator or sworn translation. An existing Spanish or English version may not suit every procedure, but further translation is not automatically necessary either. Agency authorisations, manufacturers\’ declarations, GMP certificates and quality-system documents must each be assessed according to the origin of their signatures.

How can Ginkgo Advisory help with your project in Ukraine?

We begin with a solicitor-led document review, helping exporters, manufacturers, distributors and registration advisers check their certificates and coordinate the appropriate Spanish authentication and delivery steps. Depending on the documents, our work can include:

• Identifying CLV, CEX, CPP and other AEMPS documents and checking their version, destination and attachments;
• Verifying electronic files and checking that any existing apostille covers the complete certificate;
• Coordinating an appropriate Spanish electronic or paper authentication route to meet the recipient\’s requirements;
• Coordinating signature verification, diplomatic legalisation and destination-country consular legalisation where required;
• Reviewing submission requirements for paper versions, translations and separate supporting documents, and arranging delivery.

Fees and timescales depend on the document types and quantities, existing authentication, the authorities involved, translations and courier arrangements. Once we have the complete information, we explain the procedure, estimated timescale and breakdown of costs.

What to send for an assessment

• The complete AEMPS certificate PDF, all product annexes and any existing authentication documents;
• The place of use (Ukraine), the receiving organisation\’s name and the purpose of this submission;
• The recipient\’s document checklist, request for further information or written requirements;
• The product category, number of documents and any relevant authorisations or supporting certificates;
• Paper-copy and translation requirements, your preferred completion date and the delivery address.

A document-handling example for Ukraine

The following hypothetical example illustrates how the documents can be assessed.

Suppose a Ukrainian agent receives a new request for documents after the authority is renamed. Confirm the recipient and requirements first, then decide whether the existing CPP can be used or a new certificate suited to the actual purpose is needed.

AEMPS certificates for Ukraine: frequently asked questions