Enforcement of UA CLP Followed by Ukraine REACH

On November 15, 2024, Ukraine CLP, also known as UA CLP, came into effect. Similar to EU CLP, Ukraine CLP includes obligations for the classification and labelling of hazardous substances entering the market. Companies must notify the Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR) in Ukrainian to comply with this regulation. A one-year transition period has been planned for substances present in the Ukrainian market before November 15, 2024. According to this schedule, CLP notifications must be completed by November 15, 2025. New substances entering the Ukrainian market after this date must submit their CLP notification within 30 days.

Having taken an important step towards ensuring chemical safety with UA CLP, Ukraine has decided to implement Ukraine REACH on January 23, 2025. This regulation will govern the registration, evaluation, authorization, and restriction of chemicals entering the Ukrainian market.

Who Must Register under Ukraine REACH?

According to the Ukraine REACH Regulation, manufacturers or importers that produce, formulate, or import one ton or more of chemical substances annually in Ukraine must complete Ukraine REACH registration procedures. Manufacturers not based in Ukraine must appoint an Only Representative to manage their Ukraine REACH registration and related processes.

What Are the Registration Deadlines for Ukraine REACH?

The pre-registration period for Ukraine REACH is from January 26, 2025, to January 26, 2026.

The official registration deadlines are outlined in the table below:

Substances manufactured in quantities of 1,000 tonnes or more per year
Category 1A and 1B CMR substances in quantities of 1 tonne or more per year
Substances very toxic to aquatic organisms (Category H400/H410) in quantities of 100 tonnes or more per year

October 1, 2026

Substances manufactured or imported in quantities of 100–1,000 tonnes per year

June 1, 2028

Substances manufactured or imported in quantities of 1–100 tonnes per year

March 1, 2030

Additionally, companies must prepare safety data sheets (SDS) for hazardous substances and mixtures in the Ukrainian language. Companies can benefit from Chemleg’s SDS preparation services for compliant Ukranian SDSs.

Ukraine REACH Registration Procedures

Key points about Ukraine REACH registration are listed below:

Pre-registration is required for Ukraine REACH. This is mandatory for companies manufacturing or importing one ton or more of chemical substances.
Both pre-registration and official registration must be completed within the specified deadlines to ensure the safe presence of chemicals in the Ukrainian market.
In cases where multiple applicants wish to register the same chemical substance, an information exchange consortium must be formed, and a lead registrant must be selected.
After forming the consortium, an official notification must be sent to MEPR, including details of the applicants' contact information and the selected lead registrant.

ukraine reach registration steps

Companies aiming to enter the Ukrainian target market are advised to make the necessary preparations without delay.