Ukraine REACH Has Officially Entered into Force!

We are pleased to announce that UA-REACH, the Technical Regulation “On Safety of Chemical Products,” officially entered into force on Sunday, January 26th, 2025. This marks a significant milestone in the development of Ukraine’s chemical safety legislation. The resolution of the Cabinet of Ministers approving UA-REACH, which was adopted six months ago, has now come into full effect after the transitional period. You can find the resolution and download UA-REACH via this link.

Full Framework for Chemical Safety in Ukraine is Now in Force

With this milestone, Ukraine’s chemical regulatory framework is now complete. It includes:

  • Law on Chemical Safety (UA-LCS): The Ukrainian Law “On Ensuring Chemical Safety and Management of Chemical Products.”
  • UA-CLP: The Technical Regulation “On the Classification, Labeling, and Packaging of Chemical Products.”
  • UA-REACH: The Technical Regulation “On Safety of Chemical Products.”
Registration Deadlines Under UA-REACH

UA-REACH introduces three registration deadlines based on tonnage and substance type:

1. 1 October 2026:

    • Substances at ≥ 1,000 t/a.
    • CMR substances (Category 1A and 1B) at ≥ 1 t/a.
    • Substances very toxic to aquatic organisms (acute or chronic) at ≥ 100 t/a.

2. 1 June 2028: Substances at 100–1,000 t/a.
3. 1 March 2030: Substances at 1–100 t/a.

Key Points for Industry Compliance

While several practical aspects, such as the registration process and the simplified registration procedure, remain under development by the Ministry of Environmental Protection and Natural Resources (MEPR), industries must begin focusing on their approach to compliance with the new regulations.

For Non-Ukrainian Manufacturers and Formulators

Non-Ukrainian entities placing chemical substances on the Ukrainian market have the option to appoint an Only Representative (OR) to ensure compliance with the UA-LCS, UA-CLP, and UA-REACH requirements.

Pre-Registration for substance placed in Ukraine in quantities of 1 t/a or more

  • Substances placed on the Ukrainian market before January 26, 2025, must be pre-registered within the one-year transitional period, by no later than January 26, 2026.
  • Substances placed on the market after January 26, 2025, must be pre-registered within six months of their first placement on the market.
How Can REACHLaw Ukraine Help?

REACHLaw Ukraine is here to support you with UA-REACH compliance:

  • Pre-registration and registration of substances.
  • Acting as an Only Representative (OR) for non-Ukrainian manufacturers.
  • Assistance with UA-CLP and UA-LCS compliance.
For more information or tailored solutions, please contact:

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

Don’t hesitate to reach out to us for assistance in navigating these new regulatory requirements.

Join our webinar on UA-REACH pre-registration this week!

Don’t forget to sign up for our webinar Ukraine REACH Entering Into Force – First Up: Pre-Registration this Wednesday, on 29th of January, 2025, from 1:00 – 2:00 PM EET.

You can register here.

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