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On March 24, 2026, the Ministry of Economy, Environment and Agriculture of Ukraine (MoEEA) published for public consultation a draft Resolution of the Cabinet of Ministers "On Approval of the Procedure for State Registration of Chemical Substances." The draft act operationalises the registration provisions of the Law of Ukraine "On Ensuring Chemical Safety and Management of Chemical Products" by establishing a detailed procedure for the operational steps, documentation and interactions with MoEEA necessary to fulfil UAkraine REACH registration obligations.
Scope
As per the draft Procedure, registration is required where the total mass quantity of a substance placed on the market reaches 1 tonne per year or more. This quantity is calculated as the average of the manufactured, imported or supplied amounts over the previous three calendar years. Where an operator has no three‑year activity history for a given substance, the calculation is based on planned annual quantities.
Exemption
The Procedure specifies that certain substances are not subject to registration. Exemptions cover:
(i) substances that have already been duly registered by a previous actor in the supply chain, provided that the downstream user's volume is taken into account in the upstream registration;
(ii) active substances contained in plant protection products (pesticides) and in disinfectants/biocidal products; and
(iii) other substances, including those used in or for the manufacture of specific products, where the Technical Regulation on the Safety of Chemical Products (Ukraine REACH) does not apply (in whole or in part).
In addition, exemptions from the general registration obligation are also applicable for substances used exclusively in scientific or scientific‑technical research (points 31–39 of that Technical Regulation).
Registration Procedure
Under the draft, MoEEA is designated as the competent authority for state registration of chemical substances. Economic operators subject to registration obligations may appoint a legal entity in Ukraine as an authorised representative to act on their behalf in registration procedures and data‑sharing activities.
Applications for state registration must include the applicant's name, address, contact details, and registration number (foreign) or EDRPOU code (for entities registered in Ukraine), as well as corresponding information for the manufacturer. Applications can be filed either on paper or electronically via the Unified State Web Portal of Electronic Services, including through the Chemical Safety Information System.
MoEEA must decide on state registration or refusal within 30 calendar days from receipt of the application. The date of adoption of the positive decision is deemed to be the date of state registration, and registrations are granted for an indefinite period. The final registration outcomes (adoption or refusal) shall be sent to the applicant electronically through the Unified State Web Portal of Electronic Services.
Joint Registration
The draft introduces joint submission and data‑sharing mechanisms closely aligned with EU REACH practice.
Where multiple operators submit applications for the same substance, they are required to submit information jointly in accordance with the "Rules for Joint Submission of Information in Applications for State Registration of Identical Chemical Substances," approved by Cabinet of Ministers Resolution No. 1497 of 19 November 2025.
The Procedure also sets specific rules for certain categories of substances, aligning with the Technical Regulation on the Safety of Chemical Products:
registration of monomers and other substances in polymers must follow the particular provisions in point 20 of the Technical Regulation;
registration and notification of substances in articles must respect the specific conditions in points 21–25 of the Technical Regulation;
registration of substances that have already been registered in the European Union must follow special provisions in points 26–27 of the Technical Regulation;
registration of on‑site isolated intermediates, including transported intermediates, must respect the conditions in points 67–77 of the Technical Regulation.
Implication for Industry
For chemical manufacturers, importers, and distributors placing substances or mixtures on the Ukrainian market at or above 1 tonne per year, the draft procedures acts as the operational guidance to fulfill state registration requirements under Ukraine REACH. Downstream users whose substances have already been registered upstream may, under defined conditions, benefit from the exemption for already‑registered substances. Foreign companies wishing to access the Ukrainian market can appoint a Ukrainian authorised representative to manage registration and data‑sharing processes.
The draft Resolution is currently open for public consultation. Stakeholders are invited to submit comments and proposals to MoEEA within one month from the date of its publication (March 24, 2026).
