Extension of implementation timelines for UA CLP and UA REACH Regulations

It is expected that in the near future amendments will be introduced to the Technical Regulations on the Classification, Labelling and Packaging of Chemical Products (UA CLP) and the Technical Regulation on the Safety of Chemical Products (UA REACH). The draft Resolution of the Cabinet of Ministers of Ukraine has been submitted to the central executive authorities for approval.

   
Key proposed amendments to the Resolution of the Cabinet of Ministers of Ukraine No. 539 dated 10 May 2024 (UA CLP Regulation):

1. The period for placing on the market chemical products that were placed on the market before the entry into force of the Technical Regulation and do not comply with its requirements is extended from one year to 18 months.

Accordingly, the deadline for submitting data on hazard classification and information on the hazards of chemical substances, as provided for in paragraph 126 of the Regulation, is postponed from 15 November 2025 to 15 May 2026.

2. It is envisaged that chemical products placed on the market before 1 January 2027 may remain on the market until 1 July 2028, even if their labelling and/or packaging do not fully comply with the updated requirements of Sections 3 and 4 of the Regulation.

This provision establishes a transition period for warehouses, distributors, and importers who have stocks of products bearing the previous labelling.

3. The final deadline for placing on the market chemical substances not classified as hazardous under the criteria specified in paragraphs 3.11.2.1–3.11.2.3, 4.2.2.1–4.2.2.3, 4.3.2.1–4.3.2.4, 4.4.2.1–4.4.2.4 of Annex I to the Regulation, and for which hazard information is not required under paragraphs 3.11.4.1, 4.2.4.1, 4.3.4.1, and 4.4.4.1 of Annex I, is proposed to be postponed from 1 November 2026 to 15 November 2027.

The draft also provides for amendments to the Resolution of the Cabinet of Ministers of Ukraine No. 847 dated 23 July 2024, which approved the Technical Regulation on the Safety of Chemical Products (UA REACH Regulation): 

1. The transitional period for the full implementation of the Regulation’s requirements is proposed to be extended from one year to 18 months, ensuring alignment of timelines with the CLP Regulation.

2. The draft amendments propose to postpone the deadlines for completing the mandatory state registration of chemical substances, depending on the annual tonnage of manufacture or import:

• 1,000 tonnes per year or more — postponed from 1 October 2026 to 1 October 2029;
• 100 to 1,000 tonnes per year — postponed from 1 June 2028 to 1 June 2031;
• 1 to 100 tonnes per year — postponed from 1 March 2030 to 1 March 2033;
• for CMR substances (carcinogenic, mutagenic, or toxic to reproduction) of categories 1A and 1B in quantities of 1 tonne per year or more — postponed from 26 January 2026 to 1 October 2028;
• for substances hazardous to aquatic ecosystems under long-term exposure in quantities of 100 tonnes per year or more — postponed from 26 January 2026 to 1 October 2028.

Thus, the transitional periods are extended from 32 months to up to three years, providing market operators with realistic opportunities for proper preparation, dossier compilation, and submission for registration.

3. The deadline for submitting a pre-registration notification is proposed to be postponed from 26 January 2026 to 26 January 2027.

In connection with the merger of the Ministry of Environmental Protection and Natural Resources and the Ministry of Economy, the texts of both Resolutions and the respective Technical Regulations provide for the renaming of the central executive authority to the Ministry of Economy, Environment and Agriculture of Ukraine.
     

Cratia provides professional regulatory compliance services under the chemical legislation of Ukraine, including acting as an Only Representative, as well as conducting pre-registration and state registration of chemical substances.