The Blog

On 5 November 2026, the Ministry of Economy and Environment of Ukraine (MEE) published a draft resolution proposing further extensions to several key compliance deadlines and the postponement of certain requirements under Ukraine CLP and Ukraine REACH.

The proposed amendments concern Cabinet of Ministers of Ukraine Resolution No. 539 of 10 May 2024 (Ukraine CLP) and Resolution No. 847 of 23 July 2024 (Ukraine REACH).

While the draft introduces several proposed changes to the existing regulations, the most immediate developments concern the upcoming Ukraine CLP notification and Ukraine REACH pre-registration deadlines, which would be significantly postponed if the draft resolution is adopted.

Proposed New Deadlines

Ukraine CLP Notification Deadline:

• Current deadline: 6 December 2026
• Proposed new deadline: 5 December 2028

Ukraine REACH Pre-Registration Deadline:

• Current deadline: 26 January 2027
• Proposed new deadline: 26 July 2028

For Ukraine REACH, the proposed amendments would extend the pre-registration period to 42 months, resulting in the new deadline of 26 July 2028.

Importantly, these extensions are currently only proposed. The draft resolution has not yet been formally adopted, and the existing deadlines remain in force.

Reasons for the Proposed Extensions

According to the Ministry, the proposed amendments aim to provide additional time for the implementation of Ukraine CLP and Ukraine REACH, while further aligning certain chemical classification and chemical safety procedures with the corresponding EU CLP and REACH requirements.

The extensions would give businesses more time to adapt to the regulatory requirements and prepare for the relevant compliance obligations. The amendments also address certain administrative changes following the transfer of responsibilities to the Ministry of Economy and Environment of Ukraine.

The proposed extensions concern the implementation timelines and do not cancel the underlying notification, pre-registration or registration obligations.

Other Proposed Amendments and Further Analysis

REACHLaw will publish a follow-up newsletter with a detailed breakdown of all proposed amendments to the original resolutions, including changes concerning Poison Centre Notification (PCN) obligations and deadlines under Ukraine CLP.

Documents Published for Public Consultation

The Ministry has published the following documents:

• Draft Resolution of the Cabinet of Ministers of Ukraine on Amendments to Resolutions No. 539 of 10 May 2024 and No. 847 of 23 July 2024;
• Explanatory Note to the Draft Resolution;
• Draft Amendments to Resolutions No. 539 and No. 847.

Official Ministry publication: Draft Resolution and Related Documents

The draft resolution is open for public consultation, with comments and proposals invited within one month from its publication.

What This Means for Companies

If adopted, the proposed extensions would provide companies with additional time to prepare Ukraine CLP notifications and Ukraine REACH pre-registrations, including collecting the required substance information, reviewing supply chains and deciding on the appropriate compliance route.

As the changes have not yet been adopted, companies should continue their compliance preparations based on the currently applicable requirements and deadlines.

We will continue monitoring regulatory developments and share further updates as new information becomes available.

Compliance Support

We are happy to help you understand the proposed changes and their potential impact on your business, including providing support with preparing and submitting comments during the public consultation.

Depending on your needs, REACHLaw can also support you as an Only Representative or regulatory consultant through our own subsidiary in Kyiv, REACHLaw Ukraine.

Contact:

Olesia Vinterberg
Global Accounts Lead & Legal Advisor
olesia.vinterberg@reachlaw.fi