Application for Preliminary Registration of a Chemical Substance per the UA REACH Regulation

The Ministry of Environmental Protection and Natural Resources of Ukraine has published a standardized application form for the preliminary state registration (pre-registration) of a chemical substance, under paragraphs 140–146 of the Technical Regulation on the Safety of Chemical Products, approved by Resolution of the Cabinet of Ministers of Ukraine No. 847 dated July 23, 2024 (hereinafter referred to as the UA REACH Regulation).

Please note that preliminary registration is mandatory to benefit from the transitional periods during which the placing on the market of chemical products is allowed without state registration, namely:

• CMR substances (categories 1A and 1B) in quantities exceeding 1 tonne per year: until January 26, 2026;
• Substances hazardous to the aquatic environment in quantities exceeding 100 tonnes per year: until January 26, 2026;
• Substances manufactured or imported in quantities over 1,000 tonnes per year: until October 1, 2026;
• Substances manufactured or imported in quantities from 100 to 1,000 tonnes per year: until June 1, 2028;
• Substances manufactured or imported from 1 to 100 tonnes per year: until March 1, 2030.

The preliminary registration of a chemical substance must be completed within one year from the date the UA REACH Regulation enters into force, i.e., by January 26, 2026.

The application form for preliminary state registration of a chemical substance contains around 100 fields to be completed, although paragraph 141 of the UA REACH Regulation stipulates only the following required information:

• identifiers of the chemical substance;
• identification and contact details of the manufacturer or importer, or their authorized representative;
• the intended deadline for submission of the application for state registration;
• confirmation that the applicant has access to information regarding quantitative or qualitative structure–activity relationship (Q)SAR modeling and the category approach (grouping, read-across).

The preliminary registration application must be submitted electronically in the state language and accompanied by documents confirming the appointment and authority of the Authorized Representative in Ukraine, among other things. 

You can download the application form for the preliminary state registration of a chemical substance via the provided link.