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On July 23, 2024, the Cabinet of Ministers of Ukraine approved the Resolution No. 847 On the Approval of the Technical Regulation on the Safety of Chemical Products (Ukraine REACH), marking a significant step towards aligning Ukraine's chemical legislation framework with the established European REACH and ensuring a high level of protection of human health and the environment.
As per the Resolution, the Technical Regulation on the Safety of Chemical Products shall take effect from January 26, 2025. All chemical products circulated on the market shall comply with this new regulation from that date.
In general, Ukraine REACH applies to all chemical products that are produced, imported or placed on the market on the territory of Ukraine. It does not apply to the following:
radioactive materials;
temporarily stored in custom zone for re-export or transit;
non-isolated intermediate;
transportation of dangerous goods by air, sea, road, rail or inalnd waterways;
Registration Scope
The registration is applicable to any of the following conditions:
Substance on its own, manufacture/import ≥ 1 t/yr;
Substance in a mixture, manufacture/import ≥ 1 t/yr;
Substaince intended to be released in an article (≥ 0.1% concentration) , manufacture/import ≥ 1 t/yr;
On-site isolated intermediate, manufacture ≥ 1 t/yr;
Monomer or other chemical substance as part of the polymer in an amount of 2% (by mass) or more and is chemically bound, manufacture/import ≥ 1 t/yr.
The registration is not applicable to the following:
medicinal products
veterinary medicine;
food products (including flavorings and food additives);
feed (including feed ingredients and additives);
chemicals listed in Annex IV that pose a minimal risk
chemicals listed in or meet the definitions of Annex V to this Technical Regulation;
registered substances exported from Ukraine and re-imported to Ukraine
registered substances recovered in the territory of Ukraine
polymer
For chemical substances used solely for scientific and research purposes, manufacturers or importers may apply for an exemption from the Ministry of Environment.
Registration Deadline
The pre-registration deadline is set for January 26, 2026 for chemical substances that already exist in the market before Ukraine REACH takes effect.
After this transitional period, existing substances are subject to the registration deadline as follows:
Chemical substances manufactured or imported ≥ 1000 t/yr, October 1, 2026;
Chemical substances manufactured or imported 100 ~ 1,000 t/yr, June 1, 2028;
Chemical substances manufactured or imported 1 ~ 100 t/yr, March 1, 2030.
It should be noted that for CMR substances (Category 1A and 1B) ≥ 1 t/yr and substances with hazardous to aquatic environment (acute or chronic, Category 1) ≥ 100 t/yr, they will only benefit from one-year transition period and shall be registered by the end of pre-registration deadline on January 26, 2026.
Simplified Registration
For chemical substances that have been previously registered under EU REACH, the registrant may apply for the simplified registration with fewer registration dossier requirement.
Authorisation
The Ukraine REACH maintains an Authorization List of 59 highly dangerous chemicals under Annex XIV, with their latest application dates (April 1, 2027) and sunset dates (June 1, 2027).
Manufacturers, importers who wish to continue to place on the market and/or use such substances after their sunset dates shall apply for an authorisation for specific use(s) of the substance and submit it to the Ministry of Environment.
