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On 5 December 2025, the Government of Ukraine adopted significant amendments to two core chemical safety regulations: UA CLP (Resolution No. 539 of 10 May 2024) and UA REACH (Resolution No. 847 of 23 July 2024).

The objective is to align Ukrainian legislation with EU CLP and EU REACH, while providing companies with additional time to adapt during wartime conditions and operational constraints.

Main Regulatory Updates

1. UA CLP – Extended Compliance Deadlines

The updated UA CLP transitional periods give industry a structured path to gradually comply with the new hazard classification, labelling, and packaging rules.

Key Changes:

• UA CLP notification is extended until 6 December 2026.
• UA labelling and packaging compliance for chemical products placed on the market before 1 January 2027 is extended until 1 July 2028.
• Postponed CLP compliance deadlines for new hazard classes:
  • 15 November 2027 for substances
  • 1 May 2028 for mixtures

2. UA REACH – Updated Transitional Periods and Registration Deadlines

The amendments adopt an EU-style phased registration approach, giving companies a structured and predictable compliance roadmap.

Extended supply period for existing chemicals

Chemical products placed on the market before 26 January 2025 may continue to be supplied until 26 January 2027, even if they don’t yet fully comply with UA REACH requirements.

UA REACH Registration Deadlines

• CMR substances (Category 1A and 1B) ≥1 TPA - 1 October 2028
• Substances toxic to aquatic organisms (Chronic, Category 1) ≥100 TPA - 1 October 2028
• Substances ≥1000 TPA - 1 October 2029
• Substances 100–1000 TPA - 1 June 2031
• Substances 1–100 TPA - 1 March 2033

UA REACH pre-registration period has been extended until 26 January 2027, allowing companies more time to prepare dossiers.

3. Institutional Update

Following government restructuring, the Ministry of Economy, Environment and Agriculture of Ukraine (MEEA) has taken over the responsibilities for chemical safety oversight previously held by the Ministry of Environmental Protection and Natural Resources (MEPR).

As a result, all references to the MEPR in UA REACH and UA CLP regulations have been updated to the MEEA. This ensures that the new ministry assumes full authority over chemical safety enforcement, with all regulatory functions continuing uninterrupted, providing stability and continuity for businesses during the transition.

Business Impact

The updated timelines under UA CLP and UA REACH offer several advantages for industry:

• Lower regulatory pressure during wartime
• Clear and predictable compliance planning
• Extended adaptation periods for classification, labelling, and registration
• Enhanced alignment with EU chemicals legislation
• Continued market access while transitioning to updated safety requirements

These changes give companies the necessary time to update hazard classifications, revise product labels, manage inventory transitions, and prepare complete UA REACH dossier submissions.

On 19 November 2025, the Cabinet of Ministers of Ukraine adopted Resolution No. 1497 entitled “On Approval of the Rules for the Joint Submission of Information in Applications for the Registration of an Identical Chemical Substance.” The Resolution introduces procedures for the joint submission of information under Ukraine’s chemical registration framework (UA REACH), supporting data sharing and the harmonization of hazard classification while preventing duplicate testing.

Who Will Be Affected?

The rules apply to all business entities involved in registering identical chemical substances in Ukraine. This includes manufacturers, importers, and their Only Representatives and covers substances, mixtures, and other relevant chemical products.

The framework closely aligns with the principles of the EU REACH Regulation ((EC) No. 1907/2006) by promoting proportional cost-sharing, transparent communication, and efficient chemical safety assessment.

Key Requirements for Joint Submission

To submit information jointly for the registration of an identical chemical substance, applicants must:

• Form an Information Exchange Consortium or join an existing consortium.
• Designate a lead registrant authorized to act on behalf of all other participants.
• Notify the Ministry of Economy, Environment and Agriculture of Ukraine within 10 calendar days of forming the consortium, providing the contact details of all participants and the designated lead registrant.

Submission of a Joint Notification

Within 60 working days of forming the consortium, the lead registrant must submit a joint notification to the Ministry of Economy, Environment and Agriculture of Ukraine.

The joint notification may be submitted in paper or electronic form via the Unified State Web Portal of Electronic Services or through the EcoSystem digital platform (where technically available), and must be signed using a Qualified Electronic Signature or Seal, in accordance with national legislation.

Supporting Documentation Required

Each joint notification must be accompanied by the following supporting information:

• Hazard classification data for the substance.
• Summaries of hazard studies, including objectives, methods, results, and conclusions.
• A Chemical Safety Report or exposure information where a full safety assessment is not required.
• Proposals for new testing if additional data is necessary to complete the safety assessment.

Other documents required under the applicable Technical Regulation on the Safety of Chemical Products (UA REACH) may also be included.

If any submitted information changes, the lead registrant must provide updated documentation within 30 calendar days of the change.

Legislative Context

Resolution No. 1497 complements and implements the following legal acts of Ukraine:

• The Law of Ukraine “On Ensuring Chemical Safety and Management of Chemical Products”.
• The Technical Regulation on the Safety of Chemical Products (Cabinet of Ministers Resolution No. 847 of 23 July 2024).
• The Technical Regulation on Hazard Classification, Labelling and Packaging of Chemical Products (Cabinet of Ministers Resolution No. 539 of 10 May 2024).

Entry Into Force and Practical Impact

The Resolution entered into force on 25 November 2025 following its official publication. From that date, all companies intending to register identical chemical substances under UA REACH must comply with the joint submission procedure set out in the Resolution.