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On 22 October 2025, the Ministry of Economy, Environment and Agriculture of Ukraine published a draft resolution introducing extended deadlines and key updates to Ukraine’s chemical safety framework, UA REACH and UA CLP. The proposal aims to align national regulations more closely with EU REACH and CLP, while allowing companies additional time to meet compliance obligations.

Main Updates Proposed

1. Extended Compliance Deadlines

The draft resolution proposes the following extension of key deadlines under UA REACH and UA CLP, giving businesses more time to prepare:

• UA CLP notification: 15 November 2025 → 15 May 2026
• UA Labelling and Packaging compliance: 15 November 2025 → 1 July 2028
• UA REACH Pre-registration: 26 January 2026 → 26 January 2027

UA REACH Registration Deadlines – Proposed Extentions:

2. Institutional Update

Following a government restructuring in July 2025, the Ministry of Environmental Protection and Natural Resources (MEPR) was dissolved and merged with two other ministries. Its functions and responsibilities were transferred to the newly established Ministry of Economy, Environment and Agriculture of Ukraine (MEEA).

As a result, all references to MEPR in both UA REACH and UA CLP regulations are being updated to MEEA, ensuring that the new ministry assumes full authority over chemical safety oversight. All regulatory functions continue uninterrupted under MEEA, providing continuity in implementation.

Business Impact

The proposed amendments provide greater predictability and additional time for compliance planning. Companies will have additional time to:

• Prepare registration dossiers with improved data quality.
• Align classification, labelling, and packaging with updated UA CLP requirements.
• Manage inventory transitions smoothly thanks to extended grace periods.

Implementation Timeline and Consultation

The adoption date of the regulation has not yet been determined. The public consultation period will remain open for one month from publication, and stakeholders are encouraged to review the draft and submit their feedback to the Ministry of Economy, Environment and Agriculture of Ukraine and the State Regulatory Service of Ukraine.  

On 30 July 2025, Ukraine officially notified the World Trade Organization (WTO) of a draft resolution proposing amendments to its Technical Regulation on Cosmetic Products, originally adopted under Cabinet Resolution No. 65 of 20 January 2021. The proposal, submitted by the Ministry of Health of Ukraine, aims to harmonize national cosmetic legislation with Regulation (EC) No 1223/2009 of the European Union — a key step in strengthening product safety, enhancing consumer protection, and reducing trade barriers for cosmetic products.

Key Highlights of the Draft Resolution

The draft resolution introduces significant amendments to clauses 38, 39, 47, and 52 of the current Technical Regulation. It also presents updated versions of Annexes 2–6, which include lists of restricted, prohibited, and permitted substances in cosmetic formulations.

1. Alignment with EU Cosmetic Regulation (EC) No 1223/2009

The proposed changes are aimed at ensuring full compliance with updated EU standards, especially those concerning carcinogenic, mutagenic, or reprotoxic (CMR) substances. This alignment is critical for maintaining market access for Ukrainian-made cosmetics in the EU and globally.

2. Ingredient Labelling with INCI Names

To simplify labelling and reflect international practices, the amendments allow the use of INCI (International Nomenclature of Cosmetic Ingredients) names without requiring additional translations into Ukrainian. This streamlines product packaging and enhances cross-border trade efficiency.

3. Revised Labelling Requirements for Packaging

The draft introduces more specific rules for labelling on primary and secondary packaging:

   • If only primary packaging is used, all mandatory labelling elements must be included on it.

   • If secondary packaging is present, the required labelling should appear on the outer (secondary) packaging, while the primary packaging does not need to display the list of ingredients.

4. Transitional Provisions

Provisions have been included for substances listed in Annexes 2, 3, 4, 5, and 6, allowing for a transition period to help manufacturers and importers adjust to the updated requirements.

Objectives and Impact

The main objectives of the proposed amendments are:

   • Enhancing consumer information and labelling clarity.

   • Promoting regulatory harmonization with the EU.

   • Facilitating international trade by reducing technical barriers.

By updating its national regulation, Ukraine demonstrates its commitment to aligning with European standards, which is essential for improving market access and protecting consumer health and safety.

Legal and Regulatory References

   • The Law of Ukraine “On Technical Regulations and Conformity Assessment”

   • Cabinet Resolution No. 65 “On Approval of the Technical Regulation on Cosmetic Products” dated 20 January 2021

Implementation Timeline and Comment Period

The adoption and enforcement dates of the Resolution are yet to be determined. Stakeholders have a 60-day window from the notification date to review and provide feedback on the draft to the Ministry of Economy of Ukraine.