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Recently, Ukraine's Ministry of Environmental Protection and Natural Resources (MEPR) released a template for conducting pre-registration as required under Ukraine REACH.
In accordance with the transitional provisions under Ukraine REACH, manufacturers, importers, and authorized representatives (for non-Ukrainian manufacturers) must pre-register chemical substances with an annual volume of ≥1 ton (excluding exempted substances) in order to benefit from the phase-in registration. The pre-registration window is from January 26, 2025 to January 26, 2026.
Pre-registration application
To unify the approach for filling out and submitting notifications, MEPR has issued a standardized Excel-based template and filling guide. Companies should pay attention to the following during the pre-registration application process:
The form must be completed in Ukrainian;
The document must be electronically signed by an authorized representative of the company (e.g., director) using a Qualified Electronic Signature (QES);
Submission materials should include the completed form, supporting documents, and appointment letter of the authorized representative (if applicable);
Application materials should be sent to the official designated email address ([email protected]).
Similar to EU REACH, non-Ukrainian manufacturers can appoint an authorized representative to complete the pre-registration and subsequent formal registration, but must attach proof of authorization.
Challenges for formal registration
In addition to the pre-registration, the formal registration deadline for the first batch of high-risk substances (CMR 1A/1B or aquatic environment acute or chronic, Category 1) is less than a year, which is set on January 26, 2026. However, many core issues regarding the implementation of formal registration remain unclear, such as:
Availability of IT System for submitting formal registration;
Applicability of IUCLID format;
Lead registrants and data sharing;
Implemetation of simplified registration.
Companies with operations in the Ukrainian market should initiate pre-registration as soon as possible, immediately prepare for the formal registration of high-risk substances, while waiting for the official release of policy interpretation to clarify those unresolved questions.
