The Blog

Ukraine continues to move forward with the implementation of its chemicals regulatory framework, including Ukraine CLP and Ukraine REACH. The key compliance deadlines remain unchanged:

• Ukraine CLP notification deadline: 6 December 2026
• Ukraine REACH pre-registration deadline: 26 January 2027

Companies placing chemical substances or products on the Ukrainian market should continue preparing for these obligations without delay.

CLP notifications and pre-registration submissions

Submissions must be made to the Ministry of Economy and Environment of Ukraine, which is the competent authority responsible for the implementation of these requirements. The submission templates contain macros and therefore may not work on all computers. This should be taken into account when preparing submissions. All information must be submitted in the state language, Ukrainian.

The submission process requires practical planning. Forms are submitted per substance, and there is currently no bulk submission route. In addition, each document must be signed electronically using a Ukrainian qualified e-signature, which can take time when multiple substances, importers, or notification/pre-registration packages are involved. The Ministry will also need time to process the submitted notifications and pre-registrations. For these reasons, companies should not wait until the final weeks before the deadlines.

Non-Ukrainian manufacturers and compliance routes

For non-Ukrainian manufacturers, the decision between importer-led compliance and an Only Representative setup is particularly important. If Ukrainian importers handle compliance themselves, they may need access to substance information, supply chain details and other data that non-Ukrainian manufacturers may consider confidential. An Only Representative setup can help non-Ukrainian manufacturers manage compliance centrally while supporting their Ukrainian customers and protecting sensitive business information.

REACHLaw is already supporting multiple non-Ukrainian manufacturers both as group coordinator for Ukraine CLP notifications for their Ukrainian importers and as an Only Representative for a substantial number of substances under Ukraine REACH. REACHLaw provides Ukraine compliance support through its own subsidiary in Kyiv, REACHLaw Ukraine.

Compliance support

If you need support with Ukraine CLP notifications, Ukraine REACH pre-registration, Only Representative setup or overall Ukraine chemicals compliance strategy, please contact us. Our team has practical experience managing these complex processes and helping companies prepare for compliance in a controlled and efficient way. We are happy to help you prepare and comply in time for the upcoming deadlines.

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