On the 23rd of July, the Ukrainian government has approved the technical regulation for the safety of chemical products (Ukraine REACH), marking a significant step towards establishing a national chemical management system in line with European standards.
This regulation adopts the European REACH Regulation standards, advancing Ukraine’s alignment with European Union practices.
Ukraine REACH will come into force on January 23, 2025, six months after its approval. The pre-registration process will begin on this date and will last until January 23, 2026.
Important Registration Deadlines:
- October 1, 2026:
- Substances at ≥1,000 t/a
- CMR substances (Category 1A and 1B) at ≥1 t/a
- Substances very toxic to aquatic organisms (acute or chronic) at ≥100 t/a
- June 1, 2028:
- Substances at 100 – 1,000 t/a
- March 1, 2030:
- Substances at 1 – 100 t/a
Important Authorization Deadlines:
All 59 entries in Annex XIV on Authorization have a latest application date (LAD) of April 1, 2027, and a sunset date (SSD) of June 1, 2027.
Preparing for Ukraine REACH Registration
The newly proposed deadlines are more feasible than those previously planned, which is a positive development. Based on our experience with the Turkish KKDIK, starting early can be very beneficial. The approved new deadlines present a feasible, yet challenging time frame. Early action on lead registration nomination and lead dossier work is advisable to ensure compliance. While we hope that utilizing IUCLID for dossier compilation will be possible, this is still to be confirmed by the competent authority, MEPR.
At REACH Law, we suggest that companies begin their preparations for the registration process soon. This preparation includes deciding whether to become the lead registrant for Ukraine REACH on strategic substances and planning for data sharing required for Ukraine registration dossiers. Starting early and utilizing the first six months of the transitional period until Ukraine REACH comes into force can help ensure that all requirements are met comfortably by the first registration deadline in October 2026.
Foreign Manufacturers
Ukraine REACH provides the option for non-Ukrainian manufacturers and formulators to appoint an Only Representative to handle Ukraine REACH obligations. This includes pre-registration, registration, and other requirements outlined in Ukraine REACH. It is advisable to begin the selection process for an Only Representative soon, as their appointment will be necessary for the pre-registration phase starting in six months.
