Ukraine Proposes to Extend Key Compliance Deadlines under UA REACH and UA CLP

On November 5, 2026, Ukraine's Ministry of Economy and Environment released a draft resolution proposing to amend certain provisions of Cabinet of Ministers Resolution No. 847 dated 23 July 2024 (UA REACH) and Resolution No. 539 dated May 10, 2024 (UA CLP), extending several key compliance deadlines to give enterprises more preparation time to adapt to the new chemical safety requirements.

The draft resolution is currently open for public consultation for a period of one month.

Proposed Changes under UA REACH

• For chemicals already placed on the Ukrainian market before the laws enter into force, the transitional period is proposed to be extended to July 26, 2028;
• The pre-registration deadline is also expected to be postponed accordingly from January 26, 2027 to July 26, 2028;
• The registration deadlines at each stage are not adjusted in this draft.

Proposed Changes under UA CLP

For chemicals already placed on the Ukrainian market before the laws enter into force, the transitional period is proposed to be extended to December 5, 2028. The specific milestones are as follows:

Implications and Recommendations for Enterprises

The above changes are currently only a draft proposal and have not yet taken formal effect; the current deadlines remain valid until the resolution is formally adopted by the Cabinet of Ministers and officially published. Enterprises involved in the Ukrainian market are advised to:

1. Closely follow the official announcements of Ukraine's Ministry of Economy and Environment and the progress of the draft resolution;
2. Maintain the current pace of compliance preparation based on the existing deadlines, treating the extensions as additional buffer rather than a cancellation of obligations;

CIRS Services

1. UA REACH pre-registration
2. UA REACH registration
3. SDS (UA REACH & CLP)

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