Ukraine REACH: Draft Rules for Joint Submission of Information Published – Public Consultation Ongoing
On 5 June 2025, the Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR) published a draft Resolution of the Cabinet of Ministers and accompanying Rules for Joint Submission of Information in Registration Applications under Ukraine REACH. These Rules aim to define how companies registering the same chemical substance should collaborate to share data, avoid unnecessary testing, and align with EU REACH principles.
Key Elements of the Draft Rules
The Rules apply to all registrants of the same substances and introduce several new obligations:
Creation of a Data Sharing Consortium
Under the proposed Rules, companies registering same chemical substances will be required to form or join a data sharing consortium. The purpose of such consortia is to facilitate the joint submission of information, ensure consistency in hazard data, and avoid unnecessary duplication of studies, particularly vertebrate testing.
While the draft does not elaborate on the legal structure or formality of these consortia, the approach appears to align with the concept of Substance Information Exchange Forums (SIEFs) under EU REACH. This interpretation is supported by the Ukraine REACH Annex XVIII Comparison Table, which links Articles 147–151 on Data Sharing Consortia to Article 29 of the EU REACH Regulation on SIEFs. Accordingly, it is expected that the Ukrainian model will follow a similarly flexible and collaborative framework rather than requiring the establishment of formal legal entities.
Lead Registrant Nomination
The draft Rules require that each data sharing consortium appoint a lead registrant to act on behalf of all consortium members in submitting the joint registration dossier. The lead registrant will be responsible for coordinating the submission and ensuring the completeness and accuracy of the shared data.
An open question remains regarding how this requirement applies to registrants following the simplified registration pathway under Articles 26–27 of the Law on Chemical Safety of Ukraine REACH (i.e., for substances already registered under EU REACH). It is not yet clear whether such registrants will also be obligated to join a data sharing consortium or if alternative procedures will apply. Further clarification from the Ministry is expected.
Joint Notification
A “joint notification” must be submitted by the lead registrant within 10 working days of the consortium’s creation. This joint notification should include the contact details of all members, the substance ID, and the nominated lead.
Information Requirements
Under the draft Rules, the joint notification submitted by the lead registrant must include hazard classification data, summaries of study results, the Chemical Safety Report or Exposure Scenarios (where applicable), and any proposals for new testing.
However, this requirement raises practical concerns. In “standard” REACH procedures, such information is typically provided in the lead registration dossier submission phase after the lead registrant has been nominated and confirmed by co-registrants. At the nomination stage, documents such as the study results, the CSR and Exposure Scenarios are usually not yet available. Instead, after the nomination, the lead registrant begins collecting data and studies and preparation of the lead dossier. Before the work can start the lead will discuss with co-registrants on key elements such as the Substance Identity Profile (SIP), which must be jointly agreed.
It is currently unclear whether the draft Rules intend to merge the lead nomination and dossier submission phases, or whether the terminology creates this confusion. Clarification from the Ministry would support smoother implementation and alignment with EU-REACH practices.
Updates and Responsibility
Any changes to submitted information must be reported within 10 working days, and the lead registrant is responsible for the accuracy of all data submitted.
Official Documents for Review
The draft package includes the following documents, now available on MEPR’s website:
- Draft Resolution
- Explanatory Note
- Rules
- Notice of Publication
Legal Basis and Public Consultation
The Rules were prepared based on Article 38 of the Law of Ukraine “On Ensuring Chemical Safety and Management of Chemical Products” (LCS). This article calls for clear procedures on joint submissions for identical substances.
Deadline for public comments: 5 July 2025
Stakeholders are invited to submit feedback to MEPR at:
Email: info@mepr.gov.ua
Post: вул. Митрополита Василя Липківського, 35, м. Київ, 03035
Official publication and documents available at: ПОВІДОМЛЕННЯ про оприлюднення проєкту постанови Кабінету Міністрів України «Про затвердження Правил спільного подання інформації у заявах про проведення державної реєстрації ідентичної хімічної речовини» – Міністерство захисту довкілля та природних ресурсів України
What This Means for Companies
This publication demonstrates MEPR’s clear intention and preparedness to implement registration and joint submission under UA-REACH. It is a positive and practical step forward, reflecting progress toward a functioning registration system aligned with EU practice. At the same time, several elements of the proposed Rules will require further clarification before final adoption – particularly regarding the content of the lead nomination notification. Ideally, the final approach will mirror the well-established EU REACH process, where detailed information such as the Chemical Safety Report is submitted at a later stage as part of the lead dossier and not during the nomination phase.
At REACHLaw, we are happy to support you with your compliance needs under UA-REACH and related regulations.
For further information, please contact:
Olesia Vinterberg
Global Accounts Lead & Legal Advisor
Email: Olesia.vinterberg@reachlaw.fi