Ukraine’s Progressive Steps Towards Implementing Ukraine REACH and CLP

Amidst its current challenges, Ukraine is advancing significantly in the area of chemical regulation by moving towards the adoption of its own REACH and CLP regulations. The recent submission of the draft regulations to the World Trade Organization (WTO) highlights Ukraine’s commitment to aligning with international safety standards, suggesting a potential earlier-than-expected implementation.

Ukraine REACH

Ukraine’s draft REACH regulation closely mirrors the EU’s framework, offering international companies a familiar and structured approach. This includes adopting the concept of an Only Representative to aid non-Ukrainian manufacturers in complying with Ukraine’s REACH requirements. A crucial compliance aspect is the deadline for companies to pre-register their substances, set at one year from Ukraine REACH’s effective date.

While the regulation itself does not specify registration deadlines, these are detailed in the Draft Decree on the approval of Ukraine REACH. The deadlines are distributed over different tonnage bands, with key dates set for June 1st in 2025, 2026, and 2027. Additionally, for substances that require authorization, the pertinent deadlines are specified in the draft Annex XIV.

Furthermore, Ukraine REACH proposes a simplified registration process for substances already registered under EU REACH. However, the exact details of this simplified process are still pending clarification from the relevant authorities.

Ukraine CLP

The planned adoption of Ukraine’s CLP regulation, closely mirroring the EU’s version as reported to the WTO, didn’t unfold as initially anticipated. This development is key, as it demonstrates Ukraine’s initiative to align its chemical classification and labeling with global standards, a crucial step for enhancing safety and transparency in the chemical industry. Interestingly, the submission of Ukraine REACH to the WTO occurred after the CLP submission, and notably, the implementation date for REACH was no longer specified. This might be due to the fact that the proposed implementation date for CLP did not materialize. Given these developments, it seems plausible that Ukraine might be considering a simultaneous rollout of both the REACH and CLP regulations.

Final Remarks

Ukraine’s determined efforts to establish its own REACH and CLP regulations, even amidst current challenges, reflect a deep commitment to enhancing chemical safety and harmonizing with global standards. While the precise implementation dates for these regulations are yet to be confirmed, the recent submissions to the WTO indicate a possible expedited timeline.

For further details on Ukraine’s REACH and CLP initiatives and other related developments, please reach out to our Global Accounts Lead and Legal Advisor, Olesia Vinterberg, at


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