UA-REACH & CLP – Extensions to Key Deadlines Published

  • December 9, 2025
  • Olesia Vinterberg, Global Accounts Lead and Legal Advisor

On 5 December 2025, the Cabinet of Ministers of Ukraine (KMU) approved Resolution No. 1598, extending several key deadlines under both the Ukraine REACH and Ukraine CLP regulations, as well as the implementing resolutions that brought these regulations into force. The Resolution enters into force upon publication in the official gazette.

The draft was initially proposed by the Ministry of Economy, Environment and Agriculture of Ukraine (MEEA), the competent authority for these regulations, but the KMU introduced certain changes before adoption.

New Approved Deadlines

UA-CLP Notification Deadline:

  • Original: 15 November 2025
  • Amended: Twelve months after publication in the official gazette (i.e., 6 December 2026) *

* The resolution temporarily relaxes UA-CLP requirements for 12 months from its entry into force when chemical products may be placed on the market without complying with UA-CLP. In practice, this is how the UA CLP notification deadline – and other related obligations – have been effectively extended.

UA-REACH Pre-Registration Deadline:

  • Original: 26 January 2026
  • Amended: 26 January 2027

UA-REACH Registration Deadlines:

Substance Type / Tonnage Band

Original Deadline

Amended Deadline

≥ 1 t/y CMR Cat. 1A or 1B substances, and ≥100 t/y substances
very toxic to aquatic organisms (acute or chronic)

26 Jan 2026

1 Oct 2028

> 1,000 t/y substances

1 Oct 2026

1 Oct 2029

100 – 1,000 t/y substances

1 Jun 2028

1 Jun 2031

1 – 100 t/y substances

1 March 2030

1 March 2033

 What This Means for Your Company

  • Pre-registrations and CLP notifications have been extended by roughly one year.
    The extension is not excessive, but it provides more time for companies to complete the required work.
  • UA-REACH registration deadlines are postponed significantly, giving companies additional time to prepare their dossiers and internal processes.

Official Government Source (in Ukrainian): New KMU Resolution
MEEA news: Authority Announcement

We recommend continuing your preparation work – especially pre-registration and CLP notification activities – without delay. The extended deadlines provide some additional time, but not enough to justify slowing down the process.

If you need an Only Representative in Ukraine, or support in navigating these changes and adjusting your registration strategy under UA-REACH and related regulations, our team is ready to assist!

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

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