News Details

On 5 November 2026, the Ministry of Economy and Environment of Ukraine published draft amendments to the UA REACH and UA CLP regulations, proposing extended compliance deadlines and adjustments to certain regulatory requirements.

The draft resolution proposes changes to Cabinet of Ministers Resolution No. 847 of 23 July 2024 (UA REACH) and Resolution No. 539 of 10 May 2024 (UA CLP). The proposed amendments aim to provide businesses with additional time to adapt to chemical safety requirements and address practical challenges in implementing the regulations.

The amendments are currently subject to public consultation and have not yet been adopted. Existing regulatory deadlines remain applicable until the relevant legislation is formally amended.

Proposed Changes to UA CLP Deadlines

The draft introduces several important changes to the implementation of Ukraine's classification, labelling and packaging requirements.

Under the proposal, chemical products that were already on the Ukrainian market before UA CLP entered into force and do not meet its requirements could continue to be supplied until 5 December 2028.

     1. Extension of the UA CLP Notification Deadline

One of the most significant proposals concerns the notification of hazardous chemical substances.

Under the draft amendments, the deadline for submitting UA CLP notifications for hazardous substances would be extended to 5 December 2028.

The currently applicable transitional notification deadline is 6 December 2026.

This extension would provide Ukrainian manufacturers and importers with additional time to prepare and submit the required information to the competent authority.

     2. Revised Deadlines for New Hazard Classes

The draft proposes revised transition dates for applying the new UA CLP hazard classes, including endocrine disruption (ED), persistent, bioaccumulative and toxic/very persistent and very bioaccumulative (PBT/vPvB), and persistent, mobile and toxic/very persistent and very mobile (PMT/vPvM).

Under the proposal, the transitional deadlines for these classification and hazard communication requirements would be 5 December 2027 for substances and 5 December 2028 for mixtures.

     3. Extended Transitional Period for Labelling, Packaging and Advertising

The draft also proposes an additional one-year transitional period for chemical products that do not comply with certain UA CLP labelling, packaging and advertising requirements.

Under the proposed provisions, substances placed on the market before 5 December 2027 could continue to be supplied until 5 December 2028, while mixtures placed on the market before 5 December 2028 could remain available until 5 December 2029.

During these periods, the supply of eligible products could not be prohibited or restricted solely due to non-compliance with the specified requirements under Sections 3 and 4 and paragraphs 134–135 of UA CLP.

     4. Changes to UFI and Poison Centre-Related Requirements

The draft addresses implementation challenges associated with the Unique Formula Identifier (UFI) and the submission of information needed for emergency health responses involving hazardous mixtures.

Under the proposal, the relevant requirements for emergency health information under paragraphs 130–133 of UA CLP, as well as the obligation to generate and include a UFI, would become applicable when Ukraine acquires EU Member State status.

The explanatory memorandum identifies the absence of the necessary national infrastructure, including a dedicated system for generating and administering UFIs, as a key reason for the proposed changes.

Proposed Extension of the UA REACH Transitional Period

For UA REACH, the draft proposes extending the transitional period applicable to chemical products already placed on the Ukrainian market before the regulation entered into force to 42 months, calculated from 26 January 2025. If adopted, the extended period would run until 26 July 2028.

The proposed extension is also expected to affect the UA REACH pre-registration timeline, potentially moving the deadline from 26 January 2027 to 26 July 2028.

The extended transitional period would provide additional time for affected businesses to bring existing chemical products into compliance with applicable UA REACH requirements, including relevant safety documentation obligations.

The existing phased full-registration deadlines are not expressly revised in the published draft.

What Do the Proposed Amendments Mean for Businesses?

If adopted, the amendments would provide additional time for certain UA REACH and UA CLP compliance activities. However, companies should not assume that the proposed extensions are already in force.

Manufacturers, importers and suppliers of chemical products should continue reviewing their regulatory obligations, including substance identification, hazard classification, Safety Data Sheets (SDS), labelling and applicable notification or registration requirements.

Companies should also monitor the progress of the draft resolution, as the final adopted provisions and deadlines may differ from the current proposal.

Public Consultation and Next Steps

The Ministry of Economy and Environment of Ukraine has opened the draft resolution for public consultation, with comments and proposals accepted for one month following its publication on 5 November 2026.

The proposed changes form part of Ukraine's ongoing efforts to align its chemical regulatory framework with EU REACH and CLP requirements while considering the practical conditions necessary for implementation.