ROHS Compliance

On October 22, 2025, the Ministry of Economy, Environment, and Agriculture of Ukraine (MEEA) issued a Draft Resolution proposing significant amendments to two key national chemical regulations the Technical Regulation on Chemical Safety (UA REACH) and the Regulation on Classification, Labelling, and Packaging of Chemicals (UA CLP).

The proposal seeks to:

· Postpone all current compliance deadlines under UA REACH and UA CLP, giving companies more time to meet registration, classification, and labelling requirements; and

· Update the names of regulatory authorities in line with recent governmental restructuring, transferring oversight responsibilities to the MEEA.

The draft resolution has been opened for a one-month public consultation period, which will conclude on November 22, 2025. During this period, stakeholders including chemical manufacturers, importers, and trade associations are invited to submit feedback before the amendments are finalized and adopted.

Key Deadline Extensions

UA CLP

1. Transition Period

The compliance deadline for chemicals already on the market has been extended from 1 year to 18 months (until May 15, 2026).

2. Labelling and Packaging

Products placed on the market before January 1, 2027, may continue to be sold until July 1, 2028, even if their labels or packaging do not yet comply with Sections 3 or 4 of the regulation.

3. Classification

The deadline for placing substances on the market that have not been classified according to UA CLP Annex I (CLP standards) has been adjusted to November 15, 2027.

The deadline for placing mixtures on the market without UA CLP Annex I classification has been extended to May 1, 2028.

UA REACH registration deadlines

Substance type/tonnage range Original deadline Original deadline

CMR substances (Category 1A/1B)

≥1 TPA

Substances with chronic aquatic

toxicity (Category 1) ≥100 TPA

1/26/2026 10/1/2028
Substances ≥1000 TPA 10/1/2026 10/1/2029
Substances 100-1000 TPA 6/1/2028 6/1/2031
Substances 1-100 TPA 3/1/2030 3/1/2033
  Original deadline Proposed postponement to
UA REACH pre-registration 1/26/2026 1/26/2027

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