Ukraine's REACH Regulations to Take Effect in 2025

Ukraine's REACH regulation will officially take effect on January 23, 2025.

Pre-registration and registration deadlines

Pre-registration period: January 26, 2025 - January 26, 2026

The official registration deadline is divided into three phases based on the tonnage and hazard level of the substances:

• October 1, 2026: Substances produced at ≥1000 tons per year, CMR substances (Category 1A and 1B) at ≥1 ton/year, and very toxic to aquatic life substances (Category H400/H410) at ≥100 tons/year.
• June 1, 2028: Substances produced or imported at 100-1000 tons/year.
• March 1, 2030: Substances produced or imported at 1-100 tons/year.

The implementation of the Ukrainian REACH regulations marks an important step for Ukraine in aligning with EU chemical safety standards and also presents new compliance challenges for businesses. Companies need to closely monitor regulatory developments, take proactive measures, and ensure registration is completed within the specified timeframes to maintain trade activities in the Ukrainian market.

Applicants

• Importers;
• Manufacturers;
• Only Representative (OR): Non-Ukrainian manufacturers can appoint an only representative within Ukraine to carry out pre-registration and registration tasks under Ukrainian REACH.

(Substances for) Pre-registration

Substances produced or imported at a volume of 1 ton or more per year

Unlike the EU REACH, Ukrainian REACH does not differentiate between new and existing substances for pre-registration. All substances exceeding 1t/a are eligible for pre-registration.

Pre-registration process

Manufacturers, importers, or ORs must submit a chemical pre-registration application through the Ukrainian national online portal.

Pre-registration information

• The application must include identification and contact information of the manufacturer, importer, or OR.
• Chemical identification information must be provided, including the name, CAS number, molecular formula, and structural formula.

Although the Ukrainian REACH regulations have been officially announced, the relevant supporting guideline documents have not yet been issued. We have learned from relevant agencies that there is currently no system like REACH-IT under Ukrainian REACH, and pre-registration may be submitted via email to the official authorities. Pre-registration is the most cost-effective and convenient channel for businesses to enter the Ukrainian market. CIRS Group reminds companies to organize a list of chemical products and export volumes for the Ukrainian market as soon as possible. If they exceed 1t/a, they can prepare a list and start submitting pre-registrations from January 26 next year. Depending on market demand, consider whether to proceed with formal registration. CIRS Group can provide regulatory consulting, training, and subsequent only representative and chemical pre-registration services under Ukrainian REACH.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.