Ukraine Updates Compliance Timelines for UA REACH and UA CLP

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.