Ukraine Chemical Regulation

UA REACH

UA REACH Registration & Only Representative (OR) Services in Ukraine – Ensure Full Compliance and Market Access

Expanding into Ukraine’s chemical market requires compliance with the new UA REACH regulation. Many global companies struggle with complex registration rules, data preparation, and communication with authorities. GPC simplifies Ukraine REACH registration by acting as your Ukraine REACH Only Representative, managing all submissions, reports, and updates to ensure smooth market access.

What Is Ukraine REACH (UA REACH)?

Ukraine REACH, officially known as the Ukrainian Technical Regulation on the Safety of Chemical Products, entered into force on 26 January 2025. Commonly called UA REACH, it creates a comprehensive regulatory framework aligned with the European Union’s REACH Regulation (EC No 1907/2006).

The regulation governs the registration, evaluation, authorization, and restriction of chemical substances manufactured, imported, or sold in Ukraine. It applies to all chemicals exceeding one tonne per year, requiring companies to identify hazards, assess risks, and ensure safe use.

In essence, Ukraine REACH is the country’s version of the EU REACH system, protecting human health and the environment while supporting fair trade with the EU.

Regulatory Authority

The Ministry of Economy, Environmental and Agriculture of Ukraine (MEEA) is responsible for overseeing the enforcement of and compliance with the UA REACH Regulation. The Ministry is tasked with managing the registration process, evaluating compliance, and ensuring that chemical products meet the required safety standards. In addition, the Ministry has the authority to impose sanctions or corrective actions on companies that fail to meet regulatory requirements.

Why Appoint a Ukraine REACH Only Representative

Foreign companies cannot register directly under UA REACH. A Ukraine-based Only Representative (OR) must handle registration, pre-registration, and official communication with MEEA.

Working with an experienced partner like GPC ensures:

Legal representation and full regulatory compliance in Ukraine
Seamless market access without local incorporation
Efficient management of UA REACH registration and reporting

GPC serves as a reliable Ukraine REACH representative company, guiding global manufacturers through every stage of UA REACH compliance.

Mandatory Registration and Key Provisions

Under UA REACH, any company involved in the import, production, or sale of chemical substances in Ukraine must comply with the following provisions:

1. Mandatory Registration

All chemicals ≥ 1 t/y must be registered.
Technical dossiers must describe substance identity, uses, and risk-management measures.
Failure to register can result in penalties or market suspension (“no data, no market”).

2. Chemical Safety Report (CSR)

Required for ≥ 10 t/y.
Must include hazard and exposure assessments throughout the life cycle.
Add nanomaterial information where applicable.

3. Hazardous Chemicals

Substances classified as CMR (Carcinogenic, Mutagenic, Reprotoxic) or harmful to aquatic life undergo stricter assessment.

4. Pre-Registration (26 Jan 2025 – 26 Jan 2026)

Transitional phase for existing substances.
Late pre-registration available for new entries introduced before subsequent deadlines.

5. Registration Deadlines

Deadline	Category
Jan 2026	CMR 1A/1B ≥ 1 t/y or aquatic toxicity ≥ 100 t/y
Oct 2026	≥ 1 000 t/y
Jun 2028	100 – 1 000 t/y
Mar 2030	1 – 100 t/y

Update: On 22 October 2025, Ukraine’s Ministry of Economy, Environment and Agriculture published a draft resolution proposing to extend the pre-registration and registration deadlines under UA REACH. The draft is currently open for a 30-day public consultation

6. Simplified Registration

Substances already registered under EU REACH may follow a simplified UA REACH procedure if data sharing requirements are met.

UA-REACH Compliance Process

Step 1 – Technical Dossier Submission
Submit via EcoSystem Service, including:

IUPAC name and CAS number
Restrictions on use
Purity and molecular structure details
Nano-form information (if applicable)

Step 2 – Chemical Safety Report

Provide hazard control measures, exposure scenarios, and risk assessment results.

Step 3 – Classification and Labelling

Ensure compliance with UA CLP (Classification, Labelling and Packaging) rules.

Who Must Comply

Manufacturers and Importers placing substances on the Ukrainian market.
Authorized Representatives / UA Only Representative acting for foreign companies.
Downstream Users employing substances in industrial processes and maintaining safety records.

Penalties and Enforcement

Non-compliance with UA REACH can result in a range of penalties, from administrative fines to criminal sanctions, depending on the severity of the violation. Companies found to be in violation of registration requirements or safety standards may face market restrictions or revocation of their registration

UA REACH Compliance & OR Services Provided by GPC as Ukraine REACH representative company

As a leading provider of Ukraine REACH registration support, GPC offers end-to-end Ukraine OR services for international manufacturers seeking compliance under UA-REACH.
Our local team in Kyiv delivers expert guidance and regulatory management for smooth market entry.

1. Representation and Compliance Management

Serve as your official UA OR services partner for all UA REACH obligations.
Maintain legal responsibility for documentation and liaison with MEEA.
Enable compliance without the need to establish a local entity.

2. Pre-Registration Support

Manage pre-registration of existing substances (2025 – 2026).
Handle late pre-registrations for new market entries.
Ensure correct data submission through the EcoSystem Platform.

3. Exemption Assessment and Certification

Determine eligibility for UA REACH exemptions.
Prepare and issue official certificates confirming status for audits and inspections.

4. Full Registration Management

Oversee the entire UA REACH registration workflow from data collection to dossier submission.
Compile technical dossiers with usage profiles and risk-management measures.
Represent clients directly before MEEA as their UA Only Representative.

5. Spectral Analysis and Verification

Conduct spectral and spectroscopic testing to confirm composition of substances or mixtures.
Analyse and validate client data for accurate registration records.

6. Member Dossier Preparation

Develop member dossiers for joint registrations and data-sharing arrangements.
Protect confidential information while ensuring regulatory consistency.

7. Chemical Safety Report (CSR) Preparation

Create comprehensive CSRs covering hazard classification, exposure scenarios, and lifecycle controls.
Align with both UA REACH and EU REACH best practice standards.

8. Study Management and Monitoring

Coordinate physicochemical, toxicological, and ecotoxicological studies.
Supervise laboratory quality and data validation to ensure reliable results.

9. Regulatory Monitoring and Updates

Provide ongoing updates on UA REACH and UA CLP changes.
Alert clients to deadline extensions or new obligations.
Support strategic planning for long-term portfolio compliance.

Why Choose GPC as Your Ukraine REACH Representative Company

Over 15 years of global REACH experience (EU, UK, Turkey, Korea, Ukraine)
Local Kyiv office with dedicated regulatory specialists
Trusted by 1500 + international clients for representation and compliance
Recognized among reputable Ukrainian REACH representative companies offering reliable regulatory support

📍 Office 3/5, 11 Myrnoho Panasa Street, Kyiv 01011, Ukraine
📞 +38 099 089 11 06
✉️ uareach@gpcregulatory.com

Get in Touch with Our Regulatory Expert

Conclusion

UA REACH aligns Ukraine’s chemical safety standards with the EU framework, ensuring protection of health and the environment. By partnering with GPC, a leading Ukraine REACH Only Representative, you gain expert compliance guidance, efficient registration management, and secure market access in Ukraine.

Frequently Asked Questions (FAQ)

Q1. What is UA-REACH, and why does it matter to my business?
Ans: UA-REACH (Ukraine’s REACH-style chemical regulation) is the new regulatory framework for the registration, evaluation, authorisation and restriction of chemical substances in Ukraine. It aligns closely with EU REACH principles and affects any company manufacturing, importing or placing chemical substances on the Ukrainian market.

Q2. When must I register under UA-REACH?
Ans: Under UA-REACH, registration is mandatory for any substance manufactured or imported in Ukraine in quantities of 1 tonne or more per year. Specific deadlines apply depending on tonnage band, hazard classification (e.g., CMR, aquatic toxicity) and whether you already hold registration under EU REACH.

Q3. When is a Chemical Safety Report (CSR) required under UA-REACH?
Ans: A CSR becomes mandatory when your substance is manufactured or imported at quantities of 10 tonnes or more per year, and especially if the substance presents hazard classifications, PBT/vPvB or endocrine-disrupting potential.

Q4. Can I reuse my EU REACH registration data for UA-REACH?
Ans: Yes — if you already have a dossier and CSR under EU REACH, much of the scientific data and structure can typically be adapted for UA-REACH. This can significantly reduce time, cost and duplication of effort.

Q5. What is an “Only Representative” (OR) under UA-REACH, and do I need one?
Ans: An Only Representative is a Ukraine-based legal entity authorised to take on the manufacturing/importing company’s regulatory responsibilities in Ukraine. If you are a non-Ukrainian manufacturer or exporter, appointing an OR is often essential for direct registration and uninterrupted market access.

Q6. What happens if I don’t register or comply with UA-REACH?
Ans: Non-compliance can lead to substantial penalties, from administrative fines to market suspension or revocation of rights to place your substances on the Ukrainian market. “No data, no market” applies.

Q7. How does GPC Regulatory support my business with UA-REACH?
Ans: GPC offers full service support including: acting as your Only Representative, managing pre-registration and registration processes, preparing the CSR and technical dossier, developing Ukrainian-language eSDS, liaising with Ukrainian authorities and tracking regulatory changes in UA-REACH.

Q8. What are the key registration deadlines I should be aware of?
Ans: UA-REACH sets phased deadlines depending on tonnage and hazard status. For example: CMR 1A/1B or aquatic toxicity ≥100 t/y by January 2026; substances 100-1,000 t/y by June 2028; 1-100 t/y by March 2030.

Q9. Are there simplified registration routes for substances already registered under EU REACH?
Ans: Yes. Substances with existing EU REACH registration may be eligible for a simplified approach under UA-REACH, provided data-sharing requirements and other criteria are fulfilled.

Q10. How do I get started with the UA-REACH registration process?
Ans: Contact the GPC Regulatory team to schedule an initial consultation. They will assess your portfolio, help map your use and import volumes, identify required data and CSR obligations, and guide you through pre-registration and full registration steps in Ukraine.

Q11. What is the difference between pre-registration and full registration under UA-REACH?
Ans: Pre-registration allows a company to notify authorities of a substance before full registration is required, securing market access while preparing full dossier and CSR. Full registration involves submitting the complete technical dossier and CSR, including all hazard, exposure, and risk assessment data, by the applicable deadline.

Q 12. Can UA-REACH registration (pre-registration) be submitted in English?
Ans: All UA-REACH registrations, including pre-registrations, must be submitted in Ukrainian, along with the full dossier and all supporting documents.

Q13. What happens if I place a substance on the Ukrainian market after the pre-registration phase?
Ans: A substance can still undergo late pre-registration, but this must be done within six months from its first manufacture or import and before its applicable registration deadline.

Q14. Is it possible to pre-register a substance if the annual volume is below 1 tonne?
Ans: Yes, a substance can be pre-registered even below the 1-tonne threshold. This allows companies to prepare early, indicate their intent to register, and avoid disruptions if future production or imports exceed the threshold.