Ukraine Regulatory News

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 ...

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 o...

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.

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 reduces labelling complexity and aligns with international practices.

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.