The Blog

On July 23, 2024, the Ukrainian government approved the technical regulation for the safety of chemical products, known as Ukraine REACH. The full text of the regulation and the official resolution containing the registration deadlines can be accessed here. The competent authority overseeing this regulation is the Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR).

Key Dates and Deadlines

Ukraine REACH will come into force on January 26, 2025, six months after its approval. The pre-registration process will begin on this date and will last until January 26, 2026.

Important Registration Deadlines:

• October 1, 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
• June 1, 2028:
  • Substances at 100 – 1,000 t/a
• March 1, 2030:
  • Substances at 1 – 100 t/a

Important Authorization Deadlines:

All 59 entries in Annex XIV on Authorization have a latest application date (LAD) of April 1, 2027, and a sunset date (SSD) of June 1, 2027.

Preparing for Ukraine REACH Registration

The newly proposed deadlines are more feasible than those previously planned, which is a positive development. Based on our experience with the Turkey KKDIK, starting early can be very beneficial. The approved new deadlines present a feasible, yet challenging timeframe. Early action on lead registration nomination and lead dossier work is advisable to ensure compliance. While we hope that utilizing IUCLID for dossier compilation will be possible, this is still to be confirmed by the competent authority, MEPR.

At REACHLaw, we suggest that companies begin their preparations for the registration process soon. This preparation includes deciding whether to become the lead registrant for Ukraine REACH on strategic substances and planning for data sharing required for Ukraine registration dossiers. Starting early and utilizing the first six months of the transitional period until Ukraine REACH comes into force can help ensure that all requirements are met comfortably by the first registration deadline in October 2026.

Foreign Manufacturers

Ukraine REACH provides the option for non-Ukrainian manufacturers and formulators to appoint an Only Representative to handle Ukraine REACH obligations. This includes pre-registration, registration, and other requirements outlined in Ukraine REACH. It is advisable to begin the selection process for an Only Representative soon, as their appointment will be necessary for the pre-registration phase starting in six months.

Further Guidance

For further guidance and support with Ukraine REACH registration, please contact our Global Accounts Lead & Legal Advisor, Olesia Vinterberg, at Olesia.vinterberg@reachlaw.fi.

Stay tuned for more updates and detailed information on the implementation of Ukraine REACH, as we are planning a series of webinars on the topic this fall.