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The Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR) has officially released the pre-registration template for chemical substances under the Ukraine REACH Technical Regulation. This is a significant step in the implementation of the national REACH framework, enabling businesses to start pre-registering substances placed on the Ukrainian market.

Who Must Pre-Register?

As outlined in the transitional provisions of Ukraine REACH, the following actors must pre-register substances manufactured or imported at ≥1 tonne per year, unless they are specifically exempted:

• Manufacturers

• Importers

• Only Representatives (ORs) acting on behalf of non-Ukrainian entities.

Pre-registration is mandatory in order to benefit from the staggered registration deadlines and ensure continued access to the Ukrainian market.

Pre-Registration Timeline

• Start Date: 26 January 2025

• Deadline: 26 January 2026

Registration Deadlines

• 26 January 2026: CMR substances (Category 1A and 1B) above 1 tonne per year, and substances very toxic to aquatic organisms (acute or chronic) above100 tonnes per year.

• 1 October 2026: Substances above 1,000 tonnes per year.

• 1 June 2028: Substances from 100 to 1,000 tonnes per year.

• 1 March 2030: Substances from 1 to 100 tonnes per year.

Pre-Registration Template and Submission Instructions

To streamline the compliance process, the MEPR has introduced a standardized Excel-based pre-registration form, which is only available in Ukrainian.

The form must be:

• Completed per substance

• Filled out in Ukrainian

• Electronically signed using a Qualified Electronic Signature (QES)

• Submitted along with supporting documents, and (if applicable) an Only Representative appointment letter

Completed forms should be submitted to reach@mepr.gov.ua

The official template and instructions can be found on the MEPR website.

On 9 April 2025, the Ministry of Environmental Protection and Natural Resources of Ukraine announced the development of an official CLP notification form to standardize the submission process for hazard classification and safety information of chemical products. This initiative aims to unify the approach for companies in Ukraine and ensure consistent and efficient compliance with the Technical Regulation on Classification, Labelling, and Packaging of Chemical Products (UA-CLP).

On 15 November 2024, Ukraine officially enforced the UA-CLP, implementing the Globally Harmonized System (GHS) into national law and aligning Ukraine’s chemical safety framework with international and EU standards.

Highlights of the UA-CLP Regulation:

• Implementation of EU-aligned criteria for classification of hazardous chemicals - covering 33 hazard classes.

• Mandatory labelling and packaging requirements for hazardous substances placed on the market in Ukraine.   

Obligation to Notify Hazard Classification

Under the UA-CLP Regulation, manufacturers, importers, suppliers, and other market operators must classify their chemical products before placing them on the market. The classification must follow GHS criteria. In addition, operators are required to submit a notification to the Ministry of Environmental Protection and Natural Resources of Ukraine (Ministry of Environment) with detailed information on:

• The hazard classification

• Associated safety information for each chemical substance

Introduction of Unified CLP Notification Form

To streamline compliance, the Ministry of Environment has introduced an official CLP notification form. This form ensures a consistent approach to preparing and submitting hazard classification notifications, simplifying compliance for companies across Ukraine.

Important:

• Only Ukrainian manufacturers and importers are obligated to submit the CLP notification.

• Only Representatives under Ukraine REACH may submit the notification voluntarily.

• The notification must be completed and submitted in Ukrainian and must be signed using a qualified digital signature.

How to Submit the Notification

1. Download the official form from the Ministry of Environment website (link here).

2. Complete the form with accurate classification and safety details and sign the document electronically.

3. Submit it via email to clp@mepr.gov.ua.

CLP Notification Deadlines

• For substances placed on the Ukrainian market before 15 November 2024: notification due by 15 November 2025

• For substances introduced after 15 November 2024: notification due within 30 days of first placing on the Ukrainian market.

By complying with the UA-CLP requirements and submitting timely notifications, companies will contribute to improved chemical safety and demonstrate alignment with global regulatory practices.