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Over the past few days, we have received some questions regarding the registration deadline for specific hazard classes that were initially indicated as falling under the first Ukraine REACH (UA-REACH) registration deadline of 1 October 2026, together with substances exceeding 1 000 t/y. However, based on a re-interpretation of the Resolution on Approval of UA-REACH, it has become evident that the deferred registration deadlines do not apply to these select hazard classes.

This means that CMR substances (Category 1A and 1B) at ≥ 1 t/a and substances very toxic to aquatic organisms (acute or chronic) at ≥ 100 t/a will only benefit from a one-year transitional period if they were placed on the Ukrainian market before UA-REACH entered into force (26 January 2025). In practice, this means that these substances must be fully registered by the pre-registration deadline, 26 January 2026 – which is also one month before the Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR) was originally supposed to publish the pre-registration inventory (results) for pre-SIEF communications.

This requirement goes beyond how EU-REACH was implemented and was not explicitly discussed during the Public Consultation (PC) during the spring of 2024, which is why the difference in the interpretation of registration deadlines and substance categories has only recently become evident.

Current UA-REACH Registration Deadlines

As of now, UA-REACH includes four (4) distinct registration deadlines (based on the current text of the Resolution):

• 26 January 2026 for CMR substances (Category 1A and 1B) at ≥ 1 t/a and substances very toxic to aquatic organisms (acute or chronic) at ≥ 100 t/a.
• 1 October 2026 for substances at ≥ 1,000 t/a.
• 1 June 2028 for substances at 100 – 1,000 t/a.
• 1 March 2030 for substances at 1 – 100 t/a.

What This Means for Companies

To resolve this situation, one of the following actions will likely be necessary:

1. The Resolution could be amended to align with the originally planned EU-REACH approach, ensuring companies have enough time to access pre-registration data before the registration deadline.
2. MEPR could dynamically publish pre-registration results rather than waiting until 26 February 2026, allowing companies to identify their pre-SIEF members earlier.

For now, we are looking for MEPR to act on this matter and clarify how this will be dealt with.

Upcoming Steps: C&L Notification Form & Pre-Registration Form

We are expecting the C&L notification form to be published in the coming weeks, with the pre-registration form following shortly thereafter.

Stay tuned for further updates!

If you have any questions regarding Ukraine REACH, please feel free to reach out to our Global Accounts Lead & Legal Advisor, Olesia Vinterberg, at olesia.vinterberg@reachlaw.fi

More on the subject: Ukraine REACH & CLP – REACHLaw