On December 5, the Ukrainian Cabinet approved a resolution extending the transition periods for two major chemical safety regulations—UA-CLP and UA-REACH. The decision aims to accommodate wartime challenges and give businesses additional time to align with EU requirements. Companies are encouraged to use this extended window to plan effectively and maintain continuous compliance.
I. Regulations Covered by the Amendments
· UA-CLP: Technical Regulation on Classification, Labeling, and Packaging of Chemicals (Cabinet Decree No. 539, May 10, 2024)
· UA-REACH: Technical Regulation on Chemical Safety (Cabinet Decree No. 847, July 23, 2024)
II. Key Changes 1. Extended UA-CLP Compliance Deadlines
· Chemical products placed on the market before the regulation takes effect may continue to be supplied for one additional year.
· New implementation dates:
o November 15, 2027 – for chemical substances
o May 1, 2028 – for mixtures
2. Updated UA-REACH Registration Deadlines
· January 26, 2027 – Pre-registration of existing chemical substances
· October 1, 2029 – Substances ≥1,000 tons/year
· June 1, 2031 – Substances 100–1,000 tons/year
· March 1, 2033 – Substances 1–100 tons/year
III. Background and Outlook The official document has not yet clarified registration deadlines for CMR substances, and further updates are expected.
UA-CLP and UA-REACH represent Ukraine’s ongoing alignment with EU chemical management standards. This extension reflects the government’s consideration of industry constraints during the current situation. Companies should note that compliance activities—such as data gathering, testing, and dossier preparation—require significant time. Early preparation is advised to ensure smooth market access and long-term regulatory compliance.
