At the beginning of 2025 the Ukrainian REACH regulation, modeled on the European regulation on the registration of chemical substances, came into force. The regulation imposes an obligation to register chemical substances placed on the Ukrainian market. By 26 of January 2026, pre-registration and registration of substances classified as CMR and Aquatic hazardous in category 1 must be completed.
Due to the increased interest in REACH registration in Ukraine, we present a summary of the most important information below:
New obligation:
Registration of a substance on its own or in a mixture, manufactured or imported in quantities of more than 1 tonne per year.
Who is covered:
Manufacturer, importer or authorized representative established in the territory of Ukraine.
Does it apply to European entities:
Not directly, but appointing an authorized representative who will take over the responsibility for completing the formalities makes it easier to do business with entities in Ukraine, who are thus exempt from the obligation to register substances. Otherwise, it is the importer who must take over all administrative and information obligations.
Terms:
- 26 January 2025 – entry into force of the Ukrainian REACH regulation
- by 26 January 2026 – pre-registration of substances
- by 26 January 2026 – registration of CMR substances ≥1 t/year; substances hazardous to the environment (category 1) with a volume of ≥100 tonnes/year
- by 1 October 2026 – registration of substances in tonnage ≥1,000 t/year
- by 1 June 2028 – registration of substances in tonnage 100-1000 t/year
- by 1 March 2030 – registration of substances in tonnage 1-100 t/year
Why register your substance by 26 January 2026:
Pre-registration allows products that were present before the entry into force of the legal act to be maintained on the Ukrainian market, as well as to be used until the substance is fully registered.
What to do step by step:
- Appoint your representative in Ukraine
- Collect information about the substance or substance contained in the mixture.
- Complete the pre-registration technical document, and submit it through your designated representative.
- Send the pre-registration form to the Ministry and get a pre-registration number for your substance.
- Look for a consortium and others registering the same chemical to collaborate and submit a common dossier for the substance.
- Submit your application for full registration of your substance in good time.
Current work status for pre-registration:
- The Ministry receives more and more applications for pre-registration of substances.
- The Ministry of Ukraine accepts applications signed with an electronic signature, sent to the appropriate e-mail address.
- Once the application is submitted, a pre-registration number is assigned within a few days.
- Work is underway to implement an automated electronic system for the registration of substances.
- In February 2026, a list of substances with pre-registration will be published.
Ekotox website: https://ekotox.eu/export-services-in-ukraine/
