Ukraine-REACH Consultation Completed: Stakeholders Call for Extended Deadlines

On 29 May 2024, the Ministry of Environmental Protection and Natural Resources of Ukraine announced the completion of the public consultation process on the draft Resolution of the Cabinet of Ministers of Ukraine "On the Approval of the Technical Regulation on the Safety of Chemical Products" by, commonly referred to as Ukraine-REACH or UA-REACH.

Ukraine-REACH Consultation

I accordance with the established procedure for public consultations on issues of state policy in Ukraine, the draft Resolution was initially published on the official website of the Ministry on 22 March 2024. The public was invited to submit written suggestions and comments for a two-month period.

During this period, feedback was received from various stakeholders, including the European Business Association (EBA), the Ukrainian Association of Tobacco Manufacturers "UKRTTYUTYN", the Association of Manufacturers and Formulators of Enzyme Products (AMFEP), the European Chemical Industry Council (Cefic), the Japan Chemicals Exporters and Importers Association (JCEIA) and the American Chamber of Commerce in Ukraine.

The Ministry has reviewed all submissions and published the results on its official website, providing a table summarising the comments and suggestions from these entities and organisations.

Revisions and Recommendations for REACH Implementation in Ukraine

A general concern of stakeholders participating in the consultation was the proposed timelines for chemical registration. There are significant concerns about the feasibility of the currently proposed deadlines for each tonnage band. This concern is based on past experience with e.g. KKDIK (Turkey REACH), which required significant extensions to allow industry to comply.

The Ministry of Environmental Protection and Natural Resources has responded to the concerns by revising the compliance deadlines. The revised deadlines, based on the tonnage of existing chemicals produced or made available on the market, are as follows:

Other recommendations by stakeholders:

• Simplify the registration process, especially for substances already registered under EU REACH.

• Adopt models from other countries (e.g. Switzerland or Türkiye) to reduce redundancy and administrative burden.

• Ensure clear and consistent regulations that in line with existing legislation and international practice to facilitate implementation and compliance.

For more details on the results of the public consultation, please visit the Ministry's official website here.