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UA-REACH and UA-CLP Compliance Deadlines Officially Postponed

Dec 11, 2025
Ukraine
UA REACH
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On December 5, the Ukrainian Cabinet passed a resolution extending the compliance transition periods for two key chemical safety technical regulations (UA-CLP and UA-REACH). This move aims to address wartime contingencies and provide businesses with more time to adapt to EU standards. CIRS Group reminds relevant companies to make full use of this policy window, systematically plan ahead, and ensure continuous compliance for future trade and production.

I. The amendments involve the following two core regulations:

  • Technical Regulation on Classification, Labeling, and Packaging of Chemicals (UA-CLP) – Cabinet Decree No. 539 dated May 10, 2024.
  • Technical Regulation on Chemical Safety (UA-REACH) – Cabinet Decree No. 847 dated July 23, 2024.

II. Key amendments are as follows:

1. Extension of CLP Regulation Implementation:

Chemical products already on the market before the CLP regulation takes effect may continue to be supplied for an additional year.

New CLP compliance deadlines:

  • November 15, 2027 – Applicable to chemical substances.
  • May 1, 2028 – Applicable to mixtures.

2. UA-REACH Regulation Deadlines:

  • January 26, 2027 – Applicable to pre-registration of existing chemical substances.
  • October 1, 2029 – Applicable to substances with an annual production or import volume exceeding 1,000 tons.
  • June 1, 2031 – Applicable to substances with an annual production or import volume of 100–1,000 tons.
  • March 1, 2033 – Applicable to substances with an annual production or import volume of 1–100 tons.

III. Background and Outlook

The officially released document does not yet specify registration deadlines for CMR (Carcinogenic, Mutagenic, or Toxic for Reproduction) substances. Further confirmation is needed.

UA-CLP and UA-REACH are core regulations aligning Ukraine’s chemical management system with EU standards. This significant extension reflects the Ukrainian government’s consideration of the practical challenges faced by industries during this exceptional period. CIRS Group reminds businesses that although the deadlines have been extended, compliance work—such as data collection, testing planning, and dossier preparation—is time-consuming. Companies are advised to start preparations early, leveraging CIRS’s professional services to turn compliance challenges into stable market access advantages.

 

Further Information

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