Ukraine Chemical Inventory Information

Ukraine's Technical Regulation on Chemical Safety, commonly referred to as Ukraine REACH, is a comprehensive framework designed to align the country's chemicals management system with the European Union's REACH Regulation. This initiative underlines Ukraine's commitment to protecting human health and the environment by regulating the manufacture, import, and use of chemical substances. 

Timeline for Implementation: 

• Date of Approval: The Regulation was approved by the Government of Ukraine on July 23, 2024, through Resolution No. 847. 

• Effective Date: Ukraine REACH came into force on January 26, 2025, which marks the beginning of the compliance period for stakeholders. 

• Pre-registration Period: From January 26, 2025, to January 26, 2026, companies can pre-register existing chemical substances in order to benefit from transitional provisions. However, the transitional provisions do not apply to carcinogenic, mutagenic, or toxic for reproduction (CMR) substances in categories 1A and 1B in quantities above 1 tonne per year and to substances very toxic to aquatic organisms in quantities above 100 tonnes per year. 

• Registration Deadlines: 

• January 26, 2026: Carcinogenic, mutagenic, or toxic for reproduction (CMR) substances in categories 1A and 1B at in quantities above 1 tonne per year; and substances very toxic to aquatic organisms in quantities above 100 tonnes per year.  

• October 1, 2026: Substances manufactured or imported in quantities above 1,000 tonnes per year 

• June 1, 2028: Substances manufactured or imported in quantities of 100 to1,000 tonnes per year. 

• March 1, 2030: Substances produced or imported in quantities of 1 to 100 tonnes per year. 

The Regulation mandates the registration of all chemical substances manufactured or imported into Ukraine in quantities exceeding 1 tonne per year. This includes substances on their own, in mixtures, or intended to be released from articles. Substances already on the market before January 26, 2025, are eligible for pre-registration during the specified period, allowing continued market access while full registration dossiers are prepared. 

Following the pre-registration period, a National Inventory of Existing Chemical Substances for which registrants have successfully pre-registered will be published on the official website of the Ministry of Environment by February 26, 2026, within one month of the pre-registration deadline. 

In line with the EU REACH framework, Ukraine REACH allows confidentiality claims for proprietary information. Companies can request that certain data, such as detailed substance compositions or specific uses, remain confidential in order to protect intellectual property and trade secrets. These requests are subject to evaluation by the competent authority in order to balance transparency with business interests. 

Regulatory Implications: 

• Listed Chemicals: Substances that are pre-registered and included in the National Inventory must comply with the standard requirements under REACH-, including classification, labelling, and the provision of safety data sheets (SDS). They are also subject to evaluation and potential authorization or restriction processes. 

Non-Listed Chemicals (new substances): Substances that have not been pre-registered or are new to the market after the date of entry into force must undergo full registration, including comprehensive hazard and risk assessments, before they can be manufactured or imported. Failure to comply may result in the responsible manufacturer or importer being banned from placing the substance on the Ukrainian market. By implementing this regulation, Ukraine aims to harmonize its chemical safety standards with those of the European Union, facilitating trade and ensuring a high level of protection for human health and the environment.