Ukraine REACH: Pre-Registration Template Now Available – Submissions Can Begin

  • May 7, 2025
  • Olesia Vinterberg, Global Accounts Lead and Legal Advisor

On 5 May 2025, the Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR) published the official pre-registration template for chemical substances under the Ukraine REACH Technical Regulation. This long-awaited development marks a key milestone in the practical implementation of Ukraine REACH, enabling companies to begin pre-registering substances placed on the Ukrainian market. 

Under the transitional provisions of the regulation, manufacturers, importers, and Only Representatives (ORs) must pre-register chemical substances placed on the market in quantities of 1 tonne per year or more, unless specifically exempted, in order to benefit from the staggered registration deadlines. The pre-registration window is open from 26 January 2025 until 26 January 2026. 

The following registration deadlines currently apply under the regulation: 

  • 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 

To support a harmonised and structured process, MEPR has published a standardised Excel-based template (macro-enabled and available in Ukrainian only), accompanied by instructions for completion, electronic signing, and submission. The form must be completed per substance in Ukrainian, which can present a notable administrative challenge for companies with large portfolios. It must be electronically signed using a qualified electronic signature (QES) by an authorised signatory (e.g. company director). The submission package must include the completed form, supporting documents, and, if applicable, a letter of appointment of the Only Representative. 

Submissions are to be sent by email to: reach@mepr.gov.ua 
Official publication and template available at: 
https://mepr.gov.ua/biznesu/nadannya-na-rynku-himichnoyi-produktsiyi/poperednya-derzhavna-reyestratsiyi-himichnyh-rechovyn/ 

As under EU REACH, Ukraine REACH Only Representatives may act on behalf of non-Ukrainian manufacturers and formulators and submit pre-registrations and later registrations. Proof of OR appointment must be included. 

While the release of the template marks a positive step forward, several aspects of the Ukraine REACH framework remain to be clarified, including: 

  • The treatment of substances with an earlier registration deadline (e.g. CMRs and certain aquatic toxicants) that precedes the end of the pre-registration window; 
  • The IT system and format to be used for full registration submissions; 
  • Whether IUCLID will be adopted for dossier preparation; 
  • How the “simplified registration” pathway will be applied in practice. 

Despite these open questions, the availability of the pre-registration template demonstrates MEPR’s ongoing commitment to the implementation of Ukraine REACH and the country’s alignment with EU chemicals safety standards. 

At REACHLaw, we are actively supporting clients through our subsidiary REACHLaw Ukraine with pre-registration and all other compliance services under Ukraine REACH, CLP or LCS. If your company needs support with the pre-registration process, Only Representation or guidance on regulatory strategy in Ukraine, our team is here to assist. 

For further information, please contact: 
Olesia Vinterberg 
Global Accounts Lead & Legal Advisor 
Email: Olesia.vinterberg@reachlaw.fi 

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