Ensure compliance with Ukraine’s new REACH and CLP regulations

April 2, 2025 

Ukraine REACH

On January 26, 2025, the Ukraine REACH Regulation entered into force, aligning Ukraine’s legal framework with the EU’s accession criteria. Under the new regulation, all Ukrainian manufacturers and importers who manufacture or import a substance exceeding 1 metric tonne per annum, unless specifically exempted, must pre-register and register their substances in Ukraine.

Pre-registration now open

The pre-registration phase is now open until January 26, 2026, with the full registration deadlines following in January 2026, October 2026, June 2028 and March 2030. The registration deadline depends on the tonnage band and hazard classification with CMR substances (Category 1A and 1B) at more than 1 metric tonne per annum and substances very toxic to aquatic organisms (acute or chronic) at more than 100 tonnes per annum, only having a one-year transitional period until a full registration is expected by January 26, 2026. The registration process itself includes a simplified procedure for companies that have already registered the substance under EU REACH as an EU manufacturer, importer or through an EU Only Representative.

Ukraine CLP Regulation

The Ukraine REACH Regulation follows closely on the heels of the Ukraine Classification, Labelling and Packaging (CLP) Regulation, which entered in to force on November 15, 2024. All chemical products (substances and mixtures) placed on the Ukrainian market must now be classified, labelled and packaged in accordance with Ukraine CLP requirements. A notification must be submitted for all hazardous substances placed on the Ukrainian market irrespective of volume. Products already on the market before the Ukraine CLP entered into force must have CLP notification submitted by November 15, 2025. For hazardous substances first placed on the market after November 15, 2024, companies have three months to submit a CLP notification.

Subtle differences

Both Ukraine REACH and CLP Regulations are modelled on EU REACH and EU CLP, with necessary adjustments to remove any references to EEA, community and member states. However, there are also some subtle differences that will impact the most hazardous chemicals on the Ukrainian market. CLP notifications are only required for hazardous chemicals, irrespective of tonnage, unlike EU REACH where non-hazardous substances subject to EU REACH registration would also require notification. Additionally, substances classified as toxic under Ukraine REACH require a separate permit known as an ‘LCS Permit Requirement’.

Both the Ukraine CLP and REACH Regulations are only available in Ukrainian, with no official English translation expected.

How can TSG Consulting help with the new Ukrainian regulations?

TSG’s regulatory experts, including Ukrainian specialists, are here to help you navigate these new regulations. We offer:

• Expert guidance on the Ukrainian-language regulatory text, providing clear answers to your questions
• Preparation and submission of pre-registrations for your Ukrainian customers, now classed as importers under Ukraine REACH
• Preparation and submission of CLP notifications for Ukrainian importers and manufacturers
• Liaison with Ukrainian authorities or your Ukrainian customers
• Compliance solutions for your continued business operations in Ukraine

Please do get in touch at [email protected] if you have any questions or need further assistance.