On 23 July 2024, the Ukrainian Government published a Resolution on the approval of Technical Regulation (commonly known as “Ukraine REACH”).  

In keeping with the trend of aligning with EU Regulations, Ukraine has adopted most of the provisions that are laid out in the EU REACH Regulation.  

Key Dates

• Entry into force: 23 January 2025, six months after its publication.

• Preliminary State registration window: between 23 January 2025 - 23 January 2026.

• State registration:

• 1 October 2026: Substances placed on the market at ≥1000 tonnes per year, Substances very toxic to aquatic organisms (acute or chronic) at ≥100 t/y and CMR substances (Cat. 1A and 1B) at ≥1 t/y

• 1 June 2028: Substances placed on the market at 100 - 1000 t/y

• 1 March 2030: Substances placed on the market at 1 - 100 t/y

Background

Ukraine first enacted the Law “On Ensuring Chemical Safety and Management of Chemical Products” in December 2022.  The Law is an important EU integration instrument aimed at ensuring the protection of public health and the environment.  

The approval of the “Technical Regulation on the Classification, Labelling and Packaging of Hazards of Chemical Products” and now the “Technical Regulation on Safety of Chemical Products”, signals the beginning of harmonising Ukraine’s chemical management laws with two major EU regulations (REACH and CLP). 

Key requirements of this regulation - “no data - no market”

The Technical Regulation on the Safety of Chemical Products requires the State registration of chemical substances placed on the market in quantities exceeding 1 t/y.  Registrants must submit an application for State registration to the Ministry of the Environment Protection and Natural Resources (MEPNR).  After State registration of a chemical substance is completed, the MEPNR enters the relevant data into the State Register of Chemical Substances.

Authorised Representative

Non-Ukrainian manufacturers/formulators can appoint an Authorised Representative in order to fulfil (preliminary) State registration obligations.  The Authorised Representative is analogous to an Only Representative under EU REACH.

Preliminary registration of existing chemicals

To benefit from the transitional registration deadlines, companies must submit a Preliminary State registration, which is similar to a pre-registration under EU REACH.

Applications for Preliminary State registration for existing chemical substances* must be submitted within one year from the date of entry into force of the Technical Regulation (23 January 2026).

*existing chemical substance is defined as a chemical substance that was provided on the market of Ukraine before the entry into force of this Technical Regulation, or that is contained in the State Register of Chemical Substances.

Simplified procedure for EU REACH registered substances

Companies can benefit from a simplified procedure for State registration if they have previously submitted an EU REACH registration.  A Simplified State registration is submitted to the MEPNR, in paper or electronic form using the portal.

Data requirements include:

• Technical dossier

• Chemical safety report (if ≥10 t/y),

• Evidence of the registration acceptance

Consortia formation

Where applicants for State registration intend to register the same chemical substance, they must form an information exchange consortium.  

The goals of creating information exchange consortia are:

• Electing a lead applicant for State registration

• Facilitating data exchange and cost-sharing (in a fair, proportionate, transparent and non-discriminatory manner)

• Agreeing on hazard classification

Where a consortium has been formed, an official notification must be sent to the MEPNR, indicating the contact details of all applicants and the selected lead applicant for State registration of a chemical substance.  

How can Yordas help?

Our team is ready to assist you with any questions you may have regarding Ukraine REACH and CLP. Please contact us at with your inquiries at info@yordasgroup.com. 

Stay tuned for further updates on how Ukraine REACH will be implemented!

About our expert

Sophie Guinard
Senior Regulatory Consultant

Sophie leads the development and delivery of chemical notification services globally, including in Asia, the Americas, the Middle East and Russia. Sophie's expertise lies in researching new notification systems, setting up and coordinating new services, delivering training and regulatory auditing.

Sophie holds an MSc in Environmental Science from Lancaster University.