Ukraine REACH

Stay compliant with Ukraine's REACH requirements

End-to-end support for Ukraine REACH compliance, covering gap analyses, preliminary state registration, full registration, Only Representative services, SDS authoring in Ukrainian, UA-CLP submissions and ongoing regulatory monitoring to safeguard your supply chain and access to the Ukrainian market.

What Is It?

Ukraine's primary chemical legislation, often called Ukraine REACH, mirrors the European Union's REACH framework. This regulation governs the manufacturing, importation, and usage of chemical substances, directly impacting not only domestic Ukrainian companies but also all global businesses exporting to this vital Eastern European market.

The core principle is "no data, no market." If a company manufactures or imports a chemical substance into Ukraine in quantities exceeding one tonne per year, they are typically mandated to pre-register and subsequently register that substance with the Ministry of Economy, Environment and Agriculture of Ukraine. This process is designed to ensure a high level of environmental and human health protection.

Foreign manufacturers must designate an Authorized Representative (similar to the EU's Only Representative) within Ukraine to manage these compliance duties locally.

Companies benefit from various transitional deadlines and compliance routes. For instance, a simplified registration process is available for substances already registered under EU REACH. Given the complexity of this new process, early action, particularly pre-registration, is essential for identifying the most efficient and effective compliance strategy.

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What We Offer

Yordas provides specialized services to help clients navigate chemical compliance in Ukraine. These services include:

  • Authorized Representative Services
  • Registration Services
  • Preliminary State Registration (Similar to an Inquiry under EU REACH)
  • State Registration (Similar to Full Registration under EU REACH)
  • Permit Services
  • Permit for Particularly Hazardous Chemical Substance (Similar to Authorization under EU REACH)
  • Toxic Chemicals Permit (A unique Ukrainian requirement)
  • Classification and Labelling
  • Notification of hazard classification and information on the hazards of a chemical substance (Similar to CLP Notification under EU REACH)
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Downstream user obligations (e.g., using registered substances within the supply chain) should be assessed.

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Importer obligations (for companies placing substance(s) or mixtures into Ukraine) must be understood and managed.

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Product categories such as plastics/additives, biocides, waste-derived materials may carry specific additional obligations under UA-REACH and related legislation.

Key Deadlines & Obligations

The Ukrainian authorities have released both final and draft extension dates for UA-REACH. It is critical to monitor developments closely; we can help you interpret draft versus final requirements and plan accordingly. The key obligations include:

  • 26 January 2025 – 26 January 2026: Required for all substances already on the Ukrainian market.
  • 26 January 2026: CMR substances ≥1 t/y and substances very toxic to aquatic organisms ≥100 t/y.
  • 1 October 2026: Substances ≥1,000 t/y.
  • 1 June 2028: Substances 100-1,000 t/y.
  • 1 March 2030: Substances 1-100 t/y.

Please note: Draft government changes may extend some of these dates. Please contact us for the latest update.

  • All hazardous substances placed on the Ukrainian market must be classified, labelled (in Ukrainian) and notified under UA-CLP requirements.

Non-Ukrainian manufacturers may appoint an Only Representative based in Ukraine to fulfil compliance obligations, enabling continued market access without a Ukrainian local entity.