Ukraine REACH
On 23 July 2024, the Ukrainian government approved the technical regulation on the “Safety of Chemical Products”, hereinafter “Ukraine REACH” (or “UA REACH”), marking a significant step towards establishing a national chemical management system in line with European standards. The regulation adopts the European REACH Regulation standards, advancing Ukraine’s alignment with European Union regulatory framework. Six (6) months after the approval, Ukraine REACH will enter into force on 23 January 2025.
Actors Affected and Requirements:
Ukraine REACH sets up a system for the Registration, Evaluation, Authorisation and Restriction of Chemicals in the Ukrainian market. It requires companies (legal entities) manufacturing/formulating substances in or importing substances (as such or as part of mixtures) into Ukraine at 1 tonne or more per year (t/a) to pre-register and register these substances at the Ministry of Environmental Protection and Natural Resources of Ukraine (“MEPR”).
Non-Ukrainian manufacturing/formulating companies that export substances to Ukraine, may, instead of having their importers take care of Ukraine REACH obligations individually, appoint a so called Only Representative (located in Ukraine) to take care of these Ukraine REACH importer obligations, meaning that each importer in Ukraine would only be considered as downstream user already covered by the compliance efforts of the Only Representative. Alternatively, the Ukrainian importer(s) can also take care of the Ukraine REACH obligations individually.
Key dates and Deadlines:
Ukraine REACH will enter into force on 23 January 2025 and the pre-registration phase is expected to last for one (1) year, until 23 January 2026, after which the substances will need to be registered by the applicable registration deadlines, depending on the annual volume and hazards of the substance, as follows:
- 1 October 2026: >1 000 t/a substances, and ≥ 1 t/a CMR 1A and 1B substances, and >100 t/a substances that are very toxic to aquatic organisms
- 1 June 2028: 100 – 1 000 t/a substances
- 1 March 2030: 1 – 100 t/a substances
The Ukraine REACH regulation also requires companies to prepare compliant SDSs in Ukrainian language for hazardous substances and mixtures and provide these to the downstream users promptly.
Ukraine CLP
The technical regulation on the “Classification, Labelling, and Packaging of Chemical Products”, hereinafter “Ukraine CLP” (or “UA CLP”), was approved on 10 May 2024 and enters into force on 10 November 2024, 6 months from the approval date. As its EU counterpart, Ukraine CLP requires classification and labelling notifications for hazardous substances placed on the Ukrainian market regardless of their annual tonnage. To comply with Ukraine CLP, classification information of the substance must be submitted to the MEPR in the Ukraine language through a Ukrainian entity. For substances that were on the Ukrainian market before the entry into force of UA CLP, before 10 November 2024, a one (1) year transitional period applies, meaning the CLP notification should be completed by 10 November 2025. For substances that are placed on the Ukrainian market for the first time after entry into force, the CLP notification needs to be completed within 30 days of that first time placing on the market date.
REACHLaw Support
At REACHLaw we would be happy to provide you with full support in navigating Ukraine REACH and CLP regulations. Our services include acting as your Only Representative, ensuring full compliance on your behalf, or serving as a dedicated service provider to assist with the pre-registration, registration, authorisation, classification and labelling of your substances.
Contact us at sales@reachlaw.fi for support and/or further information.