Ukraine Chemical Regulation

UA REACH

UA-REACH: A Comprehensive Regulatory Framework for Chemical Safety in Ukraine

Summary of UA-REACH 

On 26 January 2025, the Ukrainian Technical Regulation on the Safety of Chemical Products, commonly referred to as UA-REACH, which was adopted in July 2024, entered into force. This regulation aligns Ukraine’s chemical safety legislation with the European Union’s REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) framework. This regulation enforces strict requirements for the registration, classification, and safety management of chemical products in Ukraine. It applies to all chemical substances manufactured, imported, or sold in Ukraine in quantities exceeding one tonne per year. The regulation ensures that companies properly assess and manage risks associated with the production, use, and distribution of chemical products, thereby promoting the protection of human health and the environment. 

Who is the Regulatory Authority?

The Ministry of Environmental Protection and Natural Resources of Ukraine is responsible for overseeing the enforcement of and compliance the UA-REACH Regulation. "(《世界人权宣言》) 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. 

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 in quantities of one tonne or more per year must be registered with the Ministry of Environment. 
  • Companies must submit a technical dossier containing detailed information on the properties of the chemical substance, its intended use, and risk management measures. 
  • Non-compliance with the registration requirement may result in administrative penalties or suspension of market access for the product. 

2. Chemical Safety Report: 

  • Companies that handle chemicals in quantities exceeding 10 tonnes per year are required to submit a Chemical Safety Report that evaluates the potential risks to human health and the environment. 
  • The report must include hazard assessments, exposure scenarios, and safety measures for the entire life cycle of the chemical substance. 

3. Hazardous Chemicals:  

  • Substances that are classified as carcinogenic, mutagenic, or reprotoxic (CMRs) or that pose a significant risk to aquatic life, must undergo a stricter registration and assessment process. 

4. Pre-registration:  

  • From 26 January 2025 to 26 January 2026, companies can pre-register existing chemical substances to benefit from transitional provisions. 
  • Late pre-registration may apply for substances placed on the Ukrainian market for the first time after the pre-registration phase but before the applicable registration deadline. This must be completed within six months of the first production or import of the substance. 

5. Registration Deadlines are staggered according to the tonnage and properties of the chemical: 

  • By January 2026: For CMR substances (Category 1A and 1B) over 1 tonne per year and toxic effects to aquatic organisms (acute or chronic) over 100 tonnes per year.  
  • By October 2026: For chemicals produced or imported in quantities of 1,000 tonnes or more per year,  
  • By June 2028: For chemicals between 100 and 1,000 tonnes per year. 
  • By March 2030: For chemicals between 1 and 100 tonnes per year. 

6. Simplified registration: 

  • Substances registered under EU-REACH are subject to a simplified registration. 
  • To qualify for this procedure, the chemical must have an existing EU-REACH registration and registrants must adhere to the joint data submission as outlined in the UA-REACH framework. 

Compliance Requirements and Categorization

To comply with UA-REACH, companies must follow a structured procedure for classifying and categorizing chemicals. The key steps include: 

  1. Submission of Technical Dossier: 
  • Companies must submit a technical dossier through the DIIA Portal EcoSystem service, which provides an electronic means for documentation. 
  • The dossier must contain the following: 
    a) The name of the chemical substance as classified according to the International Union of Pure and Applied Chemistry (IUPAC).
    b)
    CAS number (if available).
    c) Detailed information on any restrictions on production or use. 

2. Chemical Safety Reports: 

  • The Chemical Safety Report (CSR) is mandatory for higher-risk chemicals and requires companies to outline hazard control measures and identify potential risks during production, use, and disposal. 
  • The CSR must detail the properties of nanomaterials if applicable, and justify the information used in the hazard assessment. 

Who Needs to Comply?

The UA-REACH Regulation applies to the following groups: 

  • Manufacturers and Importers: Any entity that manufactures or imports chemical substances into Ukraine must register its chemicals with the appropriate authorities. 
  • Authorized Representatives : Non-Ukrainian companies must appoint a Ukrainian legal entity or authorized representative to handle the registration and compliance processes. 
  • End Users: Companies that use chemicals in their industrial processes are also required to comply with UA-REACH, especially with regard to record keeping and safety assessments. 

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. 

Services for Compliance Management Support Offered by GPC

  1. 唯一代理  
    Act as the Ukraine-based representative for non-Ukraine manufacturers.  
  2. Pre-registration: Manage substance pre-registration of the substance to place it into the market.  
  3. Exemption Certificate  
    Assess eligibility for exemption and prepare and issue an exemption certificate.  
  4. 注册  
    Manage substance registration and prepare and submit the dossier to the relevant authority.  
  5. Spectral Analysis  
    Conduct spectral analysis and perform spectroscopic tests to verify the composition of substances or mixtures. Analyze and interpret spectral data received from clients.  
  6. Member Dossier  
    Preparation of member dossier including company-specific information and submission to authority.  
  7. CSR Preparation  
    Prepare Chemical Safety Reports (CSR) to comply with safety regulations.  
  8. Study Management and Monitoring – Physchem, Tox, Ecotox etc.  
    Co-ordination with labs and client for the studies.  
  9. Regulatory Updates  
    Keep clients informed of changes and updates in Ukraine regulations.  

Conclusion

UA-REACH represents a significant step towards aligning Ukraine’s chemical safety standards with those of the EU. The Regulation places strong emphasis on the safe handling, production and use of chemical substances to protect both public health and the environment. By ensuring compliance with these regulations, companies can continue to operate smoothly in the Ukrainian market while meeting global safety standards. 

For more information or assistance with registration and compliance, please contact Global Product Compliance (GPC) at compliance@gpcregulatory.com or visit www.gpcregulatory.com. 

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