Ukraine REACH Registration and Compliance Services

Introduction to Ukraine REACH

In July 2024, the Ukrainian government approved Resolution No. 847, establishing the Technical Regulation on the Safety of Chemical Products, commonly known as Ukraine REACH. This regulation, set to take effect on January 26, 2025, is closely modeled after the EU REACH framework. It establishes a comprehensive legal structure for managing chemicals in Ukraine, aiming to protect human health and the environment by adhering to the "no data, no market" principle. Under this mandate, chemical substances produced in or imported into Ukraine in quantities of 1 ton or more per year must be registered.

Entities Subject to Registration

The obligation to comply with Ukraine REACH applies to both domestic and foreign entities involved in the chemical supply chain:

• Manufacturers and Importers in Ukraine: Companies producing or bringing chemical substances into the Ukrainian market.
• Foreign Manufacturers: Entities based outside Ukraine can appoint a natural or legal person within Ukraine as an Authorized Representative, similar to the Only Representative (OR) role in the EU, to manage their registration duties.

Proregulations provides professional OR services to help international manufacturers maintain market access while protecting their confidential business information.

Exemptions under Ukraine REACH

Consistent with international standards, certain chemicals are exempt from the registration requirements under Ukraine REACH:

• Radioactive substances and substances under customs supervision.
• Non-isolated intermediates and substances used for national defense.
• Medicinal products, veterinary medicines, food products, and flavorings.
• Substances listed as low-risk in specific Annexes (IV and V).
• Chemicals transported by rail, road, inland waterway, sea, or air.

Pre-Registration and Compliance Deadlines

To facilitate a smooth transition for existing businesses, Ukraine REACH introduces a pre-registration phase. This process allows companies to continue their operations while preparing for full registration. The pre-registration period begins on January 26, 2025, and concludes on January 26, 2026.

Following pre-registration, full registration deadlines are determined based on the annual tonnage and the hazard profile of the substance:

• By October 1, 2025: Substances ≥ 1000 tons/year; CMR substances (Category 1A/1B) ≥ 1 ton/year; and substances highly hazardous to the aquatic environment (Category 1) ≥ 100 tons/year.
• By June 1, 2028: Substances in the 100–1000 tons/year range.
• By March 1, 2030: Substances in the 1–100 tons/year range.

Evaluation, Authorization, and Restriction

The Ukrainian Ministry of Environment oversees the technical assessment of substances to ensure market safety:

• Evaluation

The Ministry assesses dossiers to determine if additional information is required from the registrant.

• Authorization

Highly hazardous substances (such as CMRs, PBTs, or endocrine disruptors) are placed on a Candidate List and may eventually move to the Authorization List (Annex XIV), meaning they cannot be used without specific government approval.

• Restriction

Annex XVII contains a list of substances that are restricted or banned for specific uses or supply to the market under certain conditions.

Proregulations' Ukraine REACH Compliance Services

Our team provides localized expertise to help your business navigate the new Ukrainian chemical safety landscape.

• OR service
  We act as your legal representative in Ukraine to handle all registration requirements for foreign manufacturers.
• Pre-registration service
  Proregulations assists with timely pre-registration to ensure your business operations continue without interruption.
• Registration and dossier preparation
  We prepare and submit accurate registration dossiers to ensure full compliance with the Ministry of Environment.
• Risk assessment and management
  Our experts evaluate substance risks and provide strategies to manage compliance, including the submission of additional data where necessary.
• Ukraine REACH compliance analysis
  We conduct thorough assessments of your chemical portfolio to identify specific obligations and deadlines.

If you need to ensure your chemical products are fully compliant with the new Ukraine REACH requirements or require localized representation, please contact us.