In July 2024, Ukraine’s government approved Resolution No. 847, establishing the Technical Regulation on the Safety of Chemical Products, commonly known as Ukraine REACH. This regulation is set to take effect on January 26, 2025, and is modeled after the EU REACH framework. It sets a comprehensive legal framework for managing chemicals in Ukraine, aiming to ensure the protection of human health and the environment.

What is Ukraine REACH?

Ukraine REACH introduces a “no data, no market” principle, meaning that chemical substances produced or imported into Ukraine in quantities of 1 ton/year or more must be registered. The regulation applies to substances on their own, in mixtures, or articles, and introduces new requirements for registration, hazard classification, risk assessment, and more.

Who Must Comply with Ukraine REACH?

• Manufacturer, importer in Ukraine;
• Foreign manufacturers may appoint natural legal persons in Ukraine as authorized representatives, similar to the Only Representative (OR) under the EU REACH.

Registration Scopes Under Ukraine REACH

Chemical substances manufactured or imported in volumes of 1 ton or more per year must be registered with the Ministry of Environment in Ukraine. Additionally, companies should fulfill obligations of Evaluation, Authorization, and Restriction.

Exemptions Under Ukraine REACH

Certain chemicals are exempt from regulation or registration under Ukraine REACH, the same as EU REACH, including:

• Radioactive substances
• Substances that are subject to customs supervision
• Non-isolated intermediates
• Substances for use in national defense
• Carriage of hazardous substances by rail, road, inland waterway, sea or air
• Medicinal products
• Veterinary medicines
• Food products, flavorings, food additives
• Feed and feed additives
• Chemicals listed as low-risk in Annex IV
• Chemicals listed in Annex V
• And more…

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Registration Obligations Under Ukraine REACH

Ukraine REACH registration includes Pre-registration and Registration.

Pre-Registration

A pre-registration process is required for existing substances. It allows companies to benefit from the transitional regime and continue their chemical activities while preparing registration. The pre-registration period starts on January 26, 2025, and ends on January 26, 2026.

Registration Deadlines (Based on Tonnage and Hazard)

By Oct 1, 2026

• Substance at ≥1000 tons/year
• CMR substance (Category 1A/1B) at ≥1 tons/year
• Substance with Hazardous to Aquatic Environment (Category 1) at ≥100 tons/year

By Jun 1, 2028

• Substance at 100-1000 tons/year:

By Mar 1, 2030

• Substance at 1-100 tons/year

Other Obligations Under Ukraine REACH

The Ministry of Environment will assess substances based on their hazard classification and exposure potential. High-risk chemicals may face additional authorizations, restrictions, or bans.

Evaluation

It includes dossier evaluation and substance evaluation. The decision will be issued on whether to require more information after evaluation, and substance may be included in the authorization or restriction list.

Authorization & Restriction

• Authorization

Candidate List: The Ministry of Environment identifies hazardous substances (e.g., CMR, PBT, endocrine disruptors). This process is similar to the identification of substances of very high concern (SVHC) under EU REACH.

Authorization List (Annex XIV): Substances included in Annex XIV cannot be manufactured, imported, or used unless authorization has been granted.

• Restriction
  Restrictions List (Annex XVII): This Annex includes a list of 78 chemicals whose production, use, or supply on the market is restricted for certain conditions or banned.

How REACH24H Can Support You with Ukraine REACH Compliance

As an experienced regulatory consulting firm, REACH24H offers comprehensive compliance services to help businesses navigate Ukraine REACH requirements.

• Only Representative Service: If you’re a foreign manufacturer, we can provide Only Representative service to handle all local registration requirements.
• Pre-Registration Service: We assist with pre-registration, ensuring your business can continue operations without interruption.
• Registration Service: We can prepare and submit accurate registration dossiers to ensure timely compliance with Ukraine REACH.
• Risk Assessment & Management: Our experts evaluate the risks of your substances and provide strategies to manage compliance, including submitting additional data where necessary.
• Ukraine REACH Compliance Analysis

Why Choose REACH24H for Ukraine REACH Compliance

REACH24H is trusted by 9,000+ chemical industry clients in 20+ countries, delivering global chemical compliance solutions. Backed by 100+ experts and 15+ years of experience, we provide precise, localized support to navigate complex regulations. With 8 global branches, we’ve contributed to industry standards and earned recognition from government agencies.

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