Сonsultation

New Forms for UA REACH Pre-registration and UA CLP Notification

On 26 October 2026, the Ministry of Economy and Environment of Ukraine published an updated application form for the pre-registration of a chemical substance under the Technical Regulation on the Safety of Chemical Products (UA REACH), together with an updated form for notification of the hazard classification and hazard information for a chemical substance under the Technical Regulation on Hazard Classification, Labelling and Packaging of Chemical Products (UA CLP).

Among other updates, the UA REACH pre-registration application form reflects the revised transitional deadlines for state registration.

As a reminder, the deadline for submitting applications for the pre-registration of chemical substances is 26 January 2027.

Completion of pre-registration is a prerequisite for benefiting from the transitional periods under UA REACH. It gives manufacturers, importers and only representatives additional time to prepare for the state registration of existing chemical substances. The following deadlines apply, depending on the substance’s hazardous properties and the quantity manufactured or imported:

Chemical substance category and annual tonnage band manufactured or imported (across all products containing the substance and placed in Ukraine): 

Transitional period:

Substances classified as carcinogenic, mutagenic or toxic to reproduction, Category 1A or 1B, 1 tonne or more

Until 1 October 2028

Substances hazardous to the aquatic environment, Chronic Category 1, 100 tonnes or more

Until 1 October 2028

Other substances, 1,000 tonnes or more

Until 1 October 2029

Other substances, from 100 to less than 1,000 tonnes

Until 1 June 2031

Other substances, from 1 to less than 100 tonnes

Until 1 March 2033

These deadlines are set out in Resolution No. 847 of the Cabinet of Ministers of Ukraine, as amended by Resolution No. 1598 of 5 December 2025. Both tonnage bands and substance classification must be taken into account when determining the applicable transitional period.

A separate rule applies to companies that, after UA REACH entered into force, manufacture or import an existing chemical substance for the first time in quantities of one tonne or more per year, including as a component of other chemical products. Under paragraph 145 of the Regulation, these companies must submit a pre-registration application within six months of the date of first manufacture or import.

The transitional periods apply to the state registration of substances. The requirements for classification, labelling, packaging and notification under UA CLP must be met within their respective deadlines.

Attachments:

Cratia provides pre-registration and state registration services for chemical substances, acts as the Only Representative of foreign manufacturers, and assists with the preparation of documentation in accordance with UA REACH requirements.

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