Chemical Regulation Management in the Ukraine

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.

On 13 February 2025, Ukraine officially notified the World Trade Organization (WTO) of its Draft Law "On Making Available on the Market and Use of Biocidal Products", developed (issued) by the Ministry of Health.  This law aims to regulate the approval, production, market placement, circulation, and safe use of biocidal products and processed products, while ensuring compliance with standards for the protection of human and animal health  and the environment .

Key Objectives of the Draft Law

• Approval of Active Substances: Establishes legal provisions for the approval, renewal, or revision of active substances in biocidal products.

• State Registration: Implements procedures for state registration of biocidal products, including a simplified process.

• Market Supervision: Defines the legal framework for the safe use and circulation of biocidal products.

• Compliance with EU Regulations: Aligns with Regulation (EU) No. 528/2012 on biocidal products (BPR).

Authorized Body for Biocidal Product Evaluation

The draft law proposes the designation of an authorized state enterprise or institution under the central executive authority responsible for state healthcare policy. This body will:

• Evaluate applications for approval, renewal, or revision of active substances.

• Prepare expert opinions on state registration or refusal of registration of biocidal products.

• Provide evaluation services for a fee, as per agreements between applicants and the authorized body.

Fee Structure and Implementation

The law stipulates that:

• Fees for registration services will be calculated based on the minimum living wage for working-age individuals.

• The central executive authority will regulate the fee-setting process for evaluation services.

• The Cabinet of Ministers of Ukraine will approve the criteria and procedures for authorizing bodies.

Establishment of the State Register of Biocidal Products

In order to streamline market regulation, the law provides for:

• The establishment of the State Register of Biocidal Products by 1 January 2029.

• The modernization of the existing State Register of Disinfectants into the new registry.

Legislative Context

The draft aligns with key Ukrainian laws, including:

• “On Public Health System”

• “On Ensuring Chemical Safety and Management of Chemical Products”

• “On Veterinary Medicine”

• “On State Control Over Compliance with Legislation on Food, Feed, Animal By-products, Animal Health and Welfare”

Implementation Timeline and Comment Period

The date of adoption of the Law is yet to be determined. The Law will enter into force on the day following the day of its publication and will be enacted 36 months after its entry into force, except for specific provisions which will apply from 1 January 2029. Stakeholders have a 60-day window from the date of notification to review the draft and provide feedback to the Ministry of Economy of Ukraine.

Impact of the Draft Law

The adoption of this legislation will enhance the domestic market for biocidal products while ensuring high standards for human, animal, and environmental health. By aligning with EU regulations, Ukraine will strengthen its regulatory framework and market oversight, promoting safer and more transparent distribution of biocidal products.