Ukraine Regulatory News

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 framew...

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 Ca...

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.

On 16 June 2025, Ukraine officially notified the World Trade Organization (WTO) of a draft resolution of the titled "On Approval of the Rules for Joint Submission of Information in Applications for S...

On 16 June 2025, Ukraine officially notified the World Trade Organization (WTO) of a draft resolution of the titled "On Approval of the Rules for Joint Submission of Information in Applications for State Registration of Identical Chemical Substance”, which was issed by the Cabinet of Ministers. The draft resolution, developed by the Ministry of Environmental Protection and Natural Resources, outlines procedural requirements for joint submissions under Ukraine’s chemical registration framework, UA-REACH.  

Who Will Be Affected 

The proposed rules apply to all business entities involved in registering identical chemical substances. The rules cover substances, mixtures, and explosive or pyrotechnic articles classified under HS codes 28–38, (excluding Chapter 30 – Pharmaceuticals), and are closely aligned with the structure and principles of the EU REACH Regulation (EC) No. 1907/2006.   

Key Requirements of the Draft Rules 

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

• Form or join a data-sharing consortium (Information Exchange Consortium). 

• Designate a lead registrant, authorized to act on behalf of all participants.  

• Submit a joint notification to the Ministry of Environmental Protection and Natural Resources regarding the establishment of the consortium. 

What Is a Joint Notification 

A joint notification is a formal submission made by the lead registrant. It must include:   

• Contact details of all registrants and the lead registrant. 

• The chemical name and identifiers of the substance. 

The joint notification must be submitted within 10 working days of the consortium’s formation and may be submit in paper or electronic format via Ukraine’s Unified State Web Portal of Electronic Services or integrated government systems (including the EcoSystem digital platform) using a Qualified Electronic Signature or Seal, based on a qualified public key certificate, in compliance with national law. 

Supporting Documentation Required 

Each joint notification must be accompanied by documents that comply with the requirements set out in the Technical Regulation on the Safety of Chemical Products (UA-REACH), specifically:  

• Hazard classification data for the substance. 

• Summaries of hazard studies, including objectives, methods, results, and conclusions. 

• A chemical safety report or exposure information (where full assessment is not required). 

• Proposals for new tests, where necessary to complete the safety assessment. 

If any of the submitted information changes, the lead registrant must provide updated documentation within 10 calendar days.  

Legislative Context 

This draft regulation complements and operationalizes provisions of the following Ukrainian legal acts:   

• The Law of Ukraine “On Ensuring Chemical Safety and Management of Chemical Products”. 

• The Technical Regulation on Hazard Classification, Labelling and Packaging of Chemical Products (Cabinet Resolution No. 539 of 10 May 2024). 

• The Technical Regulation on the Safety of Chemical Products (Cabinet Resolution No. 847, 23 July 2024). 

•  

WTO Notification and International Alignment 

By notifying the WTO, Ukraine demonstrates its commitment to transparency and to aligning its chemical safety regulations with international best practices. This draft is an important step towards aligning national legislation with the EU REACH framework, in line with Ukraine’s WTO obligations and its Association Agreement with the EU. 

Implementation Timeline and Comment Period  

The adoption date of the Resolution is yet to be determined. The regulation will enter into force upon its official publication. Stakeholders have 60 days from the notification date to review the draft and provide feedback to the Ministry of Economy of Ukraine. 

On 28 May 2025, Ukraine officially notified the World Trade Organization (WTO) of the adoption of Cabinet of Ministers Resolution No. 588, titled “On Approval of the Procedure for State Registration...

On 28 May 2025, Ukraine officially notified the World Trade Organization (WTO) of the adoption of Cabinet of Ministers Resolution No. 588, titled “On Approval of the Procedure for State Registration of Hazardous Factors”, dated 21 May 2025. This important legislative act establishes a clear and structured process for the registration of chemical and biological hazardous factors, including both standalone substances and those contained within chemical products, that are manufactured, used, or imported into Ukraine.

What Does the Regulation Cover?

The Resolution defines the procedure for:

• Registration of chemical substances and biological agents classified as hazardous factors.

• Hazardous components within chemical products if intentionally released during use or present at concentrations of 10% or more.

• Substances manufactured, used, or imported into Ukraine, except those excluded under Part 4, Article 47 of the Law of Ukraine "On the Public Health System".

Key Elements of the Registration Procedure

1. Application Submission

Manufacturers, importers, or their authorized representatives may submit applications in person, by mail, or electronically.

2. Required Documentation

Applications must include:

2. • Identification data (IUPAC name, CAS number, EINECS).

   • Intended use and hazard classification.

   • A Safety Data Sheet (SDS) in Ukrainian.

   • List of confidential business information (if applicable).

3. Expert Review

Expert institutions have 30 calendar days to evaluate the submitted materials. An official contract between the applicant and the expert institution sets the evaluation fee, which is standardized for all applicants.

4. Decision and Entry into the Register

Based on the expert's recommendation, the Ministry of Health (MOH) will issue a registration decision within 10 calendar days and record the hazardous factor in the State Register. If approved, the entry must be made within 5 days of the decision.

Registration Characteristics

• Cost and Validity: Registration is free of charge and valid indefinitely, except in cases of temporary registration. It may be revoked if new hazardous properties are identified that pose risks to human health or the environment.

• Digital Access: The State Register of Hazardous Factors, an electronic information and communication system, will officially begin operation on 1 July 2025. 

• Transparency: The State Register will be maintained by the Ministry of Health and administered technically by the state enterprise “Electronic Health”.

WTO Notification and International Alignment

Ukraine’s notification to the WTO demonstrates its commitment to transparent regulatory practices and compliance with international trade obligations under the Technical Barriers to Trade (TBT) Agreement. This step aligns with Ukraine’s broader objectives under the EU-Ukraine Association Agreement, which aim to harmonize Ukrainian legislation with EU standards and promote trade integration with the European Single Market.

Implications for Businesses

Businesses handling chemical substances and products in Ukraine should:

• Comply with the new registration requirements.

• Update internal compliance processes to support electronic submissions.

• Prepare for mandatory expert reviews and possible requests for additional data.

Legal Framework

The Resolution was published and came into force on 28 May 2025 and will remain effective until 1 March 2030.

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 Regulat...

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 haza...

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 Ministr...

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.