The Blog

The Ministry of Economy and Environment of Ukraine has published a draft law proposing amendments to the Law of Ukraine “On Chemical Safety and Chemical Products Management” (Law on Chemical Safety or “LCS”).

According to the Explanatory Note, the purpose of the draft is to further align the LCS with EU chemicals legislation and international obligations. In particular, the proposed amendments are intended to implement Ukraine’s obligations under the Minamata Convention on Mercury and transpose key EU chemicals legislation, including the REACH, CLP, PIC, and Mercury Regulations, while also harmonising the LCS with Ukraine’s legislation on administrative procedure and insurance.

The publication of the draft represents another positive step in Ukraine’s continued implementation of an EU-standard chemicals regulatory framework. As the Ukrainian chemicals legislation continues to develop, businesses should continue preparing for the upcoming compliance milestones under the UA CLP and UA REACH regimes:

• UA CLP notifications: 6 December 2026
• UA REACH pre-registration: 26 January 2027

One of the more notable proposals is an amendment intended to address the current lack of a dedicated insurance mechanism for operators handling hazardous chemicals. The draft introduces a mandatory liability insurance requirement by referring to the existing Insurance Class 13 under the Law of Ukraine On Insurance. While the practical implications of this proposal will depend on the implementing rules, it is a welcome step towards addressing one of the practical implementation gaps under the current LCS framework.

The following documents are available on the Ministry’s website:

• Draft Proposal on Amendments to the Law on Chemical Safety;
• Explanatory Note to the Draft Proposal; and
• Comparison Table (current provisions vs. proposed amendments).

Consultation documents: Проєкт Закону України «Про внесення змін до деяких законів України щодо забезпечення хімічної безпеки та управління хімічною продукцією» | Міністерство економіки та довкілля України

The draft proposal is currently open for public consultation. Comments may be submitted directly through the Ministry’s website by clicking the “Add comment” icon on the consultation page.

If you have any questions regarding the proposed amendments or their potential impact on your business, please do not hesitate to contact us.

REACHLaw supports companies with compliance under the Ukrainian REACH, CLP, and Law on Chemical Safety (LCS) frameworks. We also provide Only Representative (OR) services in Ukraine through our wholly owned subsidiary, REACHLaw Ukraine.

For further information or to discuss your compliance needs, please contact Olesia Vinterberg, Global Accounts Lead & Legal Advisor, at olesia.vinterberg@reachlaw.fi.