Ukraine has developed its own REACH regulations, inspired by the European Union, to ensure chemical safety and protect human health and the environment. Ukraine REACH outlines the processes for the registration, evaluation, authorization, and restriction of chemicals, setting important deadlines and compliance requirements for companies.

1. Ukraine REACH: Key Dates and Registration Deadlines

Ukraine REACH will come into effect on January 23, 2025, with the pre-registration process starting on the same date and running until January 23, 2026. The critical registration deadlines are:

• ≥1,000 tonnes/year substances: October 1, 2026
• ≥1 tonne/year CMR substances (Category 1A and 1B): October 1, 2026
• ≥100 tonnes/year substances toxic to aquatic organisms: October 1, 2026
• 100 – 1,000 tonnes/year substances: June 1, 2028
• 1 – 100 tonnes/year substances: March 1, 2030

Authorization applications must be submitted by April 1, 2027, with the final application deadline set for June 1, 2027.

2. Registration Process and Requirements

The registration process under Ukraine REACH involves the accurate submission of data, preparation of technical dossiers, and inclusion of chemical safety reports. Key aspects of the registration process include:

• Data Sharing and Joint Registration: Ukraine REACH emphasizes joint data sharing and information exchange to encourage cooperation among companies registering the same substance, which helps reduce costs and streamline the process.
• Simplified Registration: Substances previously registered in the EU can benefit from a simplified registration procedure under Ukraine REACH. An only representative in the EU must be appointed for these substances.

3. Special Registration Scenarios and State Registration

Ukraine REACH details specific registration scenarios for substances subject to state registration. This process includes submitting technical dossiers and chemical safety reports to the Ministry of Environmental Protection and Natural Resources, utilizing government information systems and online portals.

• Confidentiality Provisions and Limited Submissions: Limited submissions apply exclusively to industrial-use substances, allowing certain formulation details to be protected. However, full composition disclosure is mandatory for consumer and professional use mixtures.

4. Registration Fees and Financial Obligations

Registration processes involve certain costs. Under UA REACH, the registration fees will be calculated and tariffed based on the tonnage band, type of registration application (joint, individual, EU REACH registered), type of registration (intermediate, full registration), and company size (large, medium, small, micro). The relevant parameters are as follows:

The final registration fee will be determined by applying the appropriate coefficients to the minimum base fee (2920 hryvnia in 2024). For example, for a full registration of a substance within the 1-10 tpa range, submitted by a large-scale company that is not EU REACH registered, the registration fee will be approximately between 300-350 EUR.

5. Only Representative Appointment Requirement

Ukraine REACH mandates that non-Ukrainian manufacturers and formulators appoint an only representative to manage compliance with registration, data sharing, and other regulatory processes. This representative plays a critical role in ensuring that foreign producers meet Ukraine REACH obligations.

6. Technical Regulations of the Ukrainian Cabinet of Ministers

Ukraine REACH is grounded in technical regulations approved by the Ukrainian Cabinet of Ministers. These regulations aim to ensure the safety of chemical products and their market availability. They establish all necessary standards and rules to maintain high safety levels during the production, marketing, and use of chemical substances.

• Purpose, Scope, and Application: The main goal of the Technical Regulations is to protect human health and the environment, facilitate the free circulation of chemical products, and promote the use of safe and innovative chemical protection methods.
• Principle of Prevention: The regulations emphasize preventing adverse effects on health and the environment, requiring manufacturers, importers, and downstream users to handle chemicals responsibly.