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Ukrainian REACH (UA-REACH)

Chemradar

Jun 15, 2026

Ukraine

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Ukrainian REACH (UA-REACH)

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I. Overview

In accordance with the Technical Regulation on the Safety of Chemical Products approved by Resolution No. 847/2024 of the Cabinet of Ministers of Ukraine dated 23 July 2024, Ukrainian REACH (also known as UA-REACH) entered into force six months after its official approval, i.e., on 23 January 2025. All chemical substances manufactured or used in Ukraine in quantities exceeding one tonne per year, unless exempted, must undergo pre-registration and registration.

The competent authority is the Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR).

II. Scope of Application

The regulation comprehensively covers all chemical substances, including those for industrial use as well as chemicals contained in everyday items such as cleaning products, paints, clothing, furniture, and electrical appliances. In principle, all chemical substances manufactured in or imported into Ukraine in quantities ≥ 1 tonne per year must be (pre-) registered, unless they are included in the explicit exemption list.

Exemptions

Radioactive substances;
Non-isolated intermediates;
Chemicals under customs supervision;
Medicinal products and veterinary medicinal products;
Cosmetics;
Medical devices;
Food, feed, food additives, and feed additives;
Biocidal products and plant protection products;
Tobacco products;
Substances listed in Annexes IV and V of the regulation.

III. (Pre-) Registration Entities

Manufacturers within Ukraine;
Importers within Ukraine;
Only Representatives (OR) within Ukraine.

OR (Only Representative): An exclusive representative of a foreign manufacturer, being a natural or legal person established in the country, with financial, administrative, and technical capabilities. With the consent of the foreign manufacturer of chemicals or mixtures, the OR acts as its exclusive representative and assumes the responsibilities and obligations prescribed by this law for importers. Producers outside Ukraine may appoint an Only Representative (OR) within Ukraine to fulfill relevant obligations.

IV. Pre-Registration

Pre-registration is a "transitional ticket" tailored by Ukrainian REACH for substances already imported or manufactured before the regulation entered into force, with an annual quantity ≥ 1 tonne. As long as the substance was already imported or manufactured before 23 July 2024, pre-registration can be completed first to secure a place, followed by full registration according to tonnage bands, thereby avoiding a "no data, no market" scenario.

1. Pre-registration period: 26 January 2025 to 26 January 2026

2. Information required for pre-registration:

Identity information of the domestic manufacturer, importer, or OR: company name, address, contact person, contact details, etc.;
Chemical identification information: name, CAS number, EC number, molecular formula, structural formula, chemical composition (including nano aspects);
Classification and labelling information of the chemical;
Intended uses;
Tonnage, etc.

Detailed substance information forms can be obtained from CIRS upon request.

3. Submission method: Pre-registration entities submit to the authority via email. Note: Documents must be submitted in Ukrainian.

Pre-registration = low-cost placeholder. Companies only need to provide a substance information questionnaire to apply for pre-registration, securing a compliance buffer period of 2–5 years. Missing this window means having to submit a full set of data, data fees, and administrative fees all at once.

V. Full Registration

Except for exempted substances, all chemical substances manufactured or imported in Ukraine with an annual tonnage ≥ 1 tonne must complete a full Technical Dossier and a Chemical Safety Report (CSR, mandatory for ≥ 10 t/a), obtain a registration number, and use it as proof of compliance for customs clearance, sales, and downstream users.

1. Full Registration Deadlines

26 January 2026: Existing substances that are CMR (Categories 1A and 1B) ≥ 1 t/a; existing substances classified as hazardous to the aquatic environment (H400 or H410) ≥ 100 t/a; new substances.
1 October 2026: Existing substances ≥ 1,000 t/a.
1 June 2028: Existing substances ≥ 100 t/a.
1 March 2030: Existing substances 1–100 t/a.

"Existing substances" refer to chemical substances already placed on the Ukrainian market before this technical regulation entered into force, or substances included in the National Chemicals Register.

"New substances" refer to chemical substances not placed on the Ukrainian market before this technical regulation entered into force, or substances not included in the National Chemicals Register.

The National Chemicals Register is still being compiled; it is expected to include (pre-)registered substances.

Tonnage	Annex VII	Annex VIII	Annex IX	Annex X
1–10	✓
10–100	✓	✓
100–1000	✓	✓	✓
1000+	✓	✓	✓	✓

2. Data Requirements (Standard Registration)

Chemical Safety Report (CSR, for ≥ 10 t/a)
Data categories are shown in the table below:

Data Requirement Categories	Annex VII	Annex VIII	Annex IX	Annex X
Physicochemical	1. State of the substance at normal temperature and pressure 2. Melting point / freezing point 3. Boiling point 4. Density 5. Vapour pressure 6. Surface tension 7. Water solubility 8. Octanol/water partition coefficient 9. Flash point 10. Flammability 11. Explosiveness 12. Auto-ignition temperature 13. Oxidising properties 14. Particle size distribution		1. Stability in organic solvents 2. Dissociation constant 3. Viscosity
Health / Toxicology	1. Acute oral toxicity 2. In vitro bacterial gene mutation study 3. Skin irritation / corrosion 4. Skin sensitisation	1. In vitro cytogenetic study in mammalian cells (micronucleus test) 2. In vitro gene mutation study in mammalian cells 3. Acute inhalation / acute dermal toxicity 4. 28-day repeated dose toxicity study 5. Screening / reproductive developmental toxicity 6. Toxicokinetic behaviour assessment	1. Sub-chronic toxicity study 2. Pre-natal developmental toxicity study	1. Two-generation reproductive toxicity study 2. Carcinogenicity study 3. Long-term repeated dose toxicity study
Environmental / Ecotoxicology	1. Short-term toxicity study on Daphnia 2. Algal growth inhibition test 3. Biodegradation	1. Short-term toxicity study on fish 2. Inhibition of activated sludge respiration test 3. Hydrolysis as a function of pH 4. Adsorption / desorption screening study	1. Long-term toxicity study on Daphnia 2. Long-term toxicity study on fish 3. Simulation test for ultimate degradation in water 4. Degradation, soil simulation, sediment tests 5. Bioaccumulation 6. Further study on adsorption / desorption 7. Short-term toxicity to terrestrial invertebrates 8. Effects on soil microorganisms 9. Short-term toxicity to plants	1. Long-term toxicity study on plants 2. Long-term toxicity study on sediment organisms 3. Long-term or reproductive toxicity to birds 4. Long-term toxicity study on terrestrial invertebrates 5. Further study on behaviour and fate in the environment

3. Simplified Registration

Simplified registration is designed specifically for enterprises that have already completed substance registration under EU REACH. Ukraine allows enterprises that have completed substance registration in the EU to directly reference their EU registration dossiers, submitting only three documents: (1) Technical Dossier; (2) EU Chemical Safety Report (CSR); (3) Registration confirmation letter exported from the REACH-IT system.

Simplified registration can avoid duplicate testing and reduce registration costs. However, an Only Representative (OR) must be appointed within Ukraine, and the company must assume subsequent update obligations. Nano-forms still require supplementary data related to nano-specific requirements.

4. Submission Method

A registration platform similar to the EU REACH-IT system is not yet fully developed. Registration entities still submit to the authority via email.

Ukrainian UA-REACH full registration is the final gate of "no data, no market." All chemical substances ≥ 1 t/a must complete the Technical Dossier + Chemical Safety Report (required for ≥ 10 t/a) before the four deadlines in 2026, 2028, and 2030, and obtain a unique registration number before they can continue to be manufactured or imported.

Companies must implement a three-step approach: first screen for exemptions, then determine the registration tonnage based on volume, and finally compress costs through data sharing or referencing existing EU dossiers. Any delay may trigger automatic customs interception, resulting in the dual risk of "sales suspension + fines."

VI. Authorisation and Restriction

Authorisation: Authorisation is required for 59 hazardous substances listed in Annex XIV of the regulation. The latest date to apply for authorisation is 1 April 2027. The compliance deadline is 1 June 2027.
Restriction: The list of substances in Annex XVII of the regulation is still being updated continuously. These substances are considered to pose uncontrollable risks to human health or the environment and are therefore subject to control.

VII. Obligations

Role	Obligation	Key Milestone
Manufacturer / Importer	Register chemicals (≥ 1 tonne/year)	Complete (pre-)registration before the respective deadline
Downstream User	Confirm use	Confirm whether the use is covered before use
All roles in the supply chain	Transmit SDS and registration number	Provide with the goods

VIII. Steps for Entrusted (Pre-)Registration

Our current partner is: Ekotox

After the company completes the full Power of Attorney (POA) and the (pre-)registration questionnaire, it sends them to Liu Wenlu in the Technical Department. Liu Wenlu conducts a preliminary review of the questionnaire and POA. If the information is deemed complete, Liu Wenlu sends an email to the partner, copying the technician. The partner then conducts further review and submission.

Pre-registration timeline:

After submitting complete information to the partner, the partner needs 1–2 weeks to submit to the authority;
There is no standard process for the authority's review time. It could range from 2 days to 2 weeks.

IX. Summary

Ukrainian REACH (UA-REACH) is "similar in framework" to EU REACH — it also implements "no data, no market." However, the differences in details are significant, and companies that blindly copy EU experience are highly likely to fall into pitfalls. The core difference can be summarised in one sentence: the EU takes a "step-by-step" approach, while Ukraine takes a "one-size-fits-all" approach.

Time Pressure

EU: Completed over ten years from 2008 to 2018.
Ukraine: To be completed over five years from 2025 to 2030, with the need to simultaneously build IT systems; the shortage of GLP laboratories is evident.

Key Action Points for Companies

Conduct a triple screening immediately: exemption list → tonnage → hazard category.
Establish a "UA-REACH dedicated ledger," distinguishing the timelines for "pre-registration-2026" and "full registration-2026/2028/2030."
Confirm the registration entity status with Ukrainian importers.
Check whether substances entering Ukraine have completed full registration under EU REACH. If so, prepare the registration dossier and CSR under REACH to get ready for simplified registration.

Ukrainian REACH is a "compact version of EU REACH." Companies need to complete pre-registration to secure a place before January 2026, and then proceed with data collection according to the four deadlines in 2026, 2028, and 2030, developing data gap analyses, searching for laboratory resources, conducting tests, preparing dossiers, and other tasks. Any delay will directly trigger a sales suspension.