Ukraine REACH and UA-CLP Compliance Deadlines: What Companies Need to Know

Companies placing chemicals on the Ukrainian market have been given additional time to prepare for Ukraine's chemical regulatory requirements.

On December 5, 2025, the Ukrainian Cabinet adopted a resolution extending the transition periods for UA-REACH and UA-CLP.

The revised schedule moves several key deadlines, but the underlying compliance requirements remain in place. For companies supplying chemicals to Ukraine, the first important date is now January 26, 2027, when pre-registration requirements begin.

What Is UA-REACH and UA-CLP?

UA-REACH is Ukraine's Technical Regulation on Chemical Safety, established under Cabinet Decree No. 847 of July 23, 2024.

The regulation governs the registration of substances manufactured or imported into Ukraine at 1 ton or more per year.

The registration deadlines are phased according to tonnage and hazard. An important difference from EU REACH is that Ukrainian REACH does not distinguish between new and existing substances at the pre-registration stage. Substances manufactured or imported at or above 1 ton per year can submit pre-registration. This makes reviewing the full substance portfolio an important first step for companies with Ukrainian market exposure.

UA-CLP is Ukraine's Technical Regulation on Classification, Labeling and Packaging of Chemicals, established under Cabinet Decree No. 539 of May 10, 2024. It covers the classification, labeling, and packaging of chemical substances and mixtures placed on the Ukrainian market.

Ukraine REACH and UA-CLP: Key Deadlines

UA-REACH

UA-CLP

Chemical products already on the Ukrainian market before the CLP regulation takes effect may continue to be supplied for an additional year under the transitional provisions.

Who Is Affected by Ukraine REACH?

The Ukrainian framework is relevant to several groups involved in placing substances on the Ukrainian market.

Importers

Importers placing substances on the Ukrainian market at or above 1 ton per year are subject to the relevant registration requirements.

Ukrainian Manufacturers

Manufacturers producing substances in Ukraine at or above 1 ton per year are also within the scope of the registration requirements.

Non-Ukrainian Manufacturers

Companies established outside Ukraine cannot register directly. A non-Ukrainian manufacturer can appoint an Only Representative (OR) in Ukraine to carry out pre-registration and registration on its behalf.

For companies using an OR, the appointment should be incorporated into the compliance planning process rather than left until the registration deadline approaches.

What Information Is Needed for Pre-Registration?

Manufacturers, importers, and Only Representatives submit the chemical pre-registration application through the Ukrainian national online portal.

The application includes:

• Identification and contact information for the manufacturer, importer, or Only Representative

• Chemical identification information, including the chemical name, CAS number, molecular formula, and structural formula

Although the information submitted at this stage is relatively straightforward, preparing an accurate portfolio and confirming which substances are in scope requires advance review of products, volumes, and substance identities.

What Does the Postponement Mean for Companies?

The postponement gives companies additional time to prepare for Ukraine REACH and UA-CLP. It does not remove the underlying obligations.

For companies with multiple substances or products on the Ukrainian market, preparation can involve:

• Reviewing the substance inventory

• Confirming annual volumes

• Checking substance identity

• Reviewing classification and hazard information

• Gathering information from suppliers

• Identifying data and testing gaps

• Coordinating registration activities

• Preparing registration dossiers

• Reviewing SDS and labeling requirements

• Appointing an Only Representative where required

The revised dates therefore provide a planning window rather than a reason to postpone compliance work.

The earliest revised UA-REACH deadline — January 26, 2027 — is the key date for companies beginning their preparation now.

How to Prepare for the Ukraine REACH Deadlines

Companies supplying chemicals to Ukraine can start by working through the following steps.

1. Build your Ukrainian substance inventory: Identify all substances manufactured or imported at or above 1 ton per year and confirm the relevant annual volumes.

2. Review hazard classifications: Check current classifications and identify substances that may fall into earlier registration phases based on their hazard properties.

3. Determine who will register: Confirm whether the registration responsibility sits with a Ukrainian manufacturer, importer, or Only Representative.

4. Appoint an Only Representative where required: Non-Ukrainian manufacturers should establish their representation arrangements early enough to support pre-registration and subsequent registration activities.

5. Identify data gaps: Assess the information available for each substance and identify any additional data, testing, or coordination required.

6. Coordinate UA-REACH and UA-CLP: UA-REACH and UA-CLP should not be considered entirely separate compliance exercises. Classification and labeling decisions can affect the hazard-based registration phase applicable to a substance.

7. Plan against the earliest deadline: Even where full registration is not required until a later date, pre-registration begins on January 26, 2027. Companies should work backward from this date when planning portfolio reviews, supplier engagement, and internal approvals.

Key Takeaway

The Ukraine REACH and UA-CLP deadlines have been postponed, but the regulatory framework remains in place. For companies supplying chemicals to Ukraine, January 26, 2027 is the first key date to work toward. Reviewing your portfolio, confirming registration responsibilities, and identifying data or representation requirements now can help establish a clear path toward the subsequent UA-REACH and UA-CLP deadlines.

Ukraine REACH and UA-CLP Compliance Support from CIRS Group

CIRS Group supports companies preparing for Ukraine's chemical regulatory requirements.

Our Ukraine REACH services include:

• Ukraine REACH consulting and training

• Ukraine REACH Only Representative services

• Ukraine REACH pre-registration

• Ukraine REACH full registration

• SDS and label preparation under UA-CLP

Whether you are reviewing your Ukrainian chemical portfolio, determining which registration deadlines apply, preparing for pre-registration, or arranging an Only Representative, CIRS Group can help you assess the requirements and establish a practical compliance timeline.

Contact CIRS Group at service@cirs-group.com to discuss your Ukraine REACH and UA-CLP requirements.