Ukraine Notifies WTO of Draft Regulation on Joint Submission Rules for Chemical Substance Registration under UA-REACH

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). 

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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.