On 5 November 2026, Ukraine's Ministry of Economy and Environment released a draft resolution proposing to amend certain provisions of Cabinet of Ministers Resolution No. 847 dated 23 July 2024 (UA REACH) and Resolution No. 539 dated 10 May 2024 (UA CLP), extending several key compliance deadlines to give enterprises more preparation time to adapt to the new chemical safety requirements.
The draft resolution is currently open for public consultation for a period of one month.
Proposed Changes under UA REACH
- For chemicals already placed on the Ukrainian market before the laws enter into force, the transitional period is proposed to be extended to 26 July 2028;
- The pre-registration deadline is also expected to be postponed accordingly from 26 January 2027 to 26 July 2028;
- The registration deadlines at each stage are not adjusted in this draft.
Proposed Changes under UA CLP
For chemicals already placed on the Ukrainian market before the laws enter into force, the transitional period is proposed to be extended to 5 December 2028. The specific milestones are as follows:
|
Item |
Deadline |
|
C&L notification (original deadline: 6 December 2026) |
5 December 2028 |
|
Labelling and packaging: substances placed on the market before 5 December 2027 |
May continue to be supplied until 5 December 2028 |
|
Labelling and packaging: mixtures placed on the market before 5 December 2028 |
May continue to be supplied until 5 December 2029 |
|
ED, PBT, vPvB, PMT and vPvM classification (substances) |
5 December 2027 |
|
ED, PBT, vPvB, PMT and vPvM classification (mixtures) |
5 December 2028 |
|
PCN poison centre notification and UFI |
The date on which Ukraine formally acquires the status of an EU member state |
Implications and Recommendations for Enterprises
The above changes are currently only a draft proposal and have not yet taken formal effect; the current deadlines remain valid until the resolution is formally adopted by the Cabinet of Ministers and officially published. Enterprises involved in the Ukrainian market are advised to:
- Closely follow the official announcements of Ukraine's Ministry of Economy and Environment and the progress of the draft resolution;
- Maintain the current pace of compliance preparation based on the existing deadlines, treating the extensions as additional buffer rather than a cancellation of obligations;
CIRS Services
- UA REACH pre-registration
- UA REACH registration
- SDS (UA REACH & CLP)
We will follow up with a timely update once the formal resolution is released.
