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Manufacturers of chemical products are racing to enter the promising Ukrainian market. The deadlines for the phased registration under the new Ukrainian REACH regulation are approaching fast, but manufacturers from outside of Ukraine will find it a complicated and even tedious task to comply with the requirements. In this brief article, we shall shortly overview the key challenges manufacturers will face while preparing for the Ukrainian REACH regulation and outline how GPC Gateway and GPC Regulatory can help to overcome them.

The Core Challenges for Non-Ukrainian Manufacturers (H2)

While local businesses are fighting their own battles to conform to the requirements of Ukraine REACH, foreign companies have their own problems connected with product compliance in the Ukrainian market. Here we will describe the major ones.

1. The Only Representative (OR) Mandate - (H3)

This manufacturer is based outside of Ukraine and is unable to register the substances on the Ukrainian inventory itself. Like EU REACH, Ukraine REACH requires a non-resident company to appoint an Only Representative (an entity based in Ukraine). An experienced Only Representative is necessary to help them comply with the Ukraine REACH regulations. This manufacturer has no pathway to the market without a qualified OR.

2. A Tight and Shifting Deadline (H3)

The compliance calendar for pre-registering hazard chemicals is extremely close with high-priority substances such as CMR 1A/1B chemicals offering little time to collect and submit required information to the EPA. Pre-registration for these substances opens on January 26, 2025, and closes on January 26, 2026, while the first deadline for formal registration for these high-priority substances is also January 26, 2026. Failing to register a substance and comply with EPA regulations could result in penalties that are more than just financial in nature and could ultimately result in the company’s product being taken off the market.

3. A Maze of Documentation & Language Barriers (H3)

The pre-registration process is time-consuming. Filling up the form in Excel in the Ukrainian language (no errors allowed) and signing it with a Qualified Electronic Signature (QES) is a relatively easy task for a company from any country. But the problem becomes twice as complicated for foreign companies, as they would need to fill the form in the language of the country where the company is registered, sign and scan it with an appropriate digital signature, and attach an additional set of documents (like an appointment letter of the Official Representative).

4. Unclear Regulatory Path Forward (H3)

One of the main problems with the implementation of the new rules for the use and sale of dangerous substances in Ukraine is that Ukraine REACH is still under development, and manufacturers and importers of products containing hazardous substances are now struggling to gather the necessary information to prepare for the forthcoming registration phase, only to find that the information they need cannot be obtained in order subsequently to complete the registration in the appropriate database. Some of the key problems are outlined below.

1. When will the official IT system for formal registrations be available?

2. Will Ukraine adopt the format of the European IUCLID? And registration dossiers for Ukraine.

3. What mechanisms will be put in place to manage the lead registrant election and data sharing?

4. What are the specific rules for "simplified registration"?

However, further clarification is required for the industry to compile the full registration dossier with certainty.

The challenges above need a strategic approach to solving the new landscape of compliance and reporting. GPC Gateway and GPC Regulatory offer a solution that combines state-of-the-art technology and value-added services to solve the new rules for compliance and regulatory reporting.

How GPC Gateway Simplifies Compliance (H2)

GPC Gateway is GPC’s powerful, web-based, central command center for the regulatory compliance portal. Focused on streamlining the “data and monitoring” aspects of the problem, GPC Gateway automates and simplifies the complex, time-consuming tasks required to stay on top of changing regulations.

Our Centralized Intelligence provides cross-border, international compliance made easy by gathering all relevant requirements for countries around the world into one database for the manufacturer to quickly reference requirements for Ukraine and other countries.

Regulations change frequently, and one missed update can have severe consequences. GPC Gateway notifies you in real time of any updates or changes.

Efficient Data Management: GPC Gateway efficiently manages data relevant to your business under regulatory jurisdictions. All of your SDS, chemical composition data, and registration dossiers are stored in a comprehensive database, allowing for easy retrieval of the information you need. Reduces the chance for error and saves you time and money.

Expert Insights & Guidance: For organisations that don't have in-house expertise, GPC Gateway provides guidance for companies with limited knowledge of the regulations.

How GPC Regulatory Provides Expert Local Representation (H2)

Although the information will reside within the portal (the GPC Gateway), the subject matter expertise will be provided by the GPC Regulatory.

1. Only Representative (OR) Services - As an international specialist in food and consumer goods regulations, GPC Regulatory can act as an Only Representative in Ukraine for non-Ukrainian manufacturers.

2. Full Compliance Roadmap: We can start from the initial regulatory assessment and classification and assist in developing a road map to achieve full compliance for you.

3. Preparation and submission of dossier, registration, and related notifications.

4. Local Liaison with Authorities: We act as a liaison with Ukrainian authorities during your application and after its approval, and deal with their inquiries.

Take Action Now (H2)

While entering the Ukrainian market can be complex for non-Ukrainian manufacturers, it is by no means insurmountable. Using the intelligent, data-driven platform of GPC Gateway, combined with the on-the-ground, globally-expert services of GPC Regulatory, manufacturers can turn what appears to be a challenge into an opportunity.

We can assist with Ukraine REACH registration services. Contact us to ensure continued market access for your chemical in Ukraine.