The legislation covers all chemical substances manufactured or imported in Ukraine in quantities of one tonne per year or more, unless specifically exempted. Its purpose is to improve chemical ­safety, strengthen supply chain responsibility, and ensure that ­businesses operating in Ukraine meet modern environmental and human health protection standards.

Pre-registration phase

To ensure a smooth transition, Ukraine has introduced a pre-registration period, similar to the early phase of EU REACH.

• Start date: January 26, 2025
• End date: January 26, 2026
• Purpose: Companies may continue manufacturing and importing while preparing their full registration dossiers. Substances that are not pre-registered by the deadline will be considered “new” and subject to immediate full registration before being placed on the Ukrainian market.

The Ministry of Environmental Protection and Natural Resources (MEPR) is the lead authority overseeing the system. To support industry, MEPR has released a standardised Excel-based pre-­registration template (macro-enabled, Ukrainian-language only), together with detailed instructions for completion, electronic signature, and submission.

Each substance must be reported individually (one form per substance), and the completed forms must be signed using a Qualified Electronic Signature (QES) by an authorised company representative. The submission package must include:

• Completed pre-registration form
• Substance Identity Profile (SIP) testing report
• Appointment letter (if using an Only Representative)

This administrative process may prove demanding, particularly for companies with large portfolios, so early preparation is strongly recommended.

Who must register?

Ukrainian manufacturers and importers of chemical substances at ≥ one tonne per year must register. Foreign manufacturers who export to Ukraine can appoint an Only Representative (OR) based in Ukraine to take over registration obligations.

What substances are covered?

UA REACH covers all substances that are manufactured or imported at quantities of one tonne or more per year. However, several exemptions apply to this general rule. Non-isolated intermediates are excluded from the regulation, as are waste materials and certain naturally occurring substances. Additionally, substances that are already regulated under other specific legislative frameworks, such as pharmaceuticals, food products, or biocides, fall outside the scope of REACH requirements. Substance Identification and Data Collection

Accurate substance identification is the foundation of compliance. Companies must provide:

• CAS number, EC number, IUPAC name
• Molecular and structural formula
• Molecular weight
• Optical activity and stereoisomer ratio (if applicable)
• Purity level and impurity profile

For nanoforms, additional information is required, including particle size distribution, crystallinity, surface treatment, and shape. This level of detail ensures that safety assessments account for the specific properties of nanoscale materials.

Registration dossier preparation

Once pre-registration is complete, companies must prepare and submit a registration dossier. This dossier is expected to mirror the EU REACH format and use IUCLID (International Uniform Chemical Information Database).The dossier contains:

• Technical dossier: substance identity, classification and labelling, safety data sheet (SDS), exposure scenarios, and safe-use guidance.
• Chemical Safety Report (CSR): required for substances ≥ ten tonnes per year, including exposure assessment and risk characterisation.

Submission and fees

Dossiers will be submitted to the MEPR or a designated competent authority. Administrative fees will apply, calculated according to tonnage band and company size (final fee schedules are expected to be confirmed shortly).

Evaluation

Authorities may carry out two types of evaluation under UA REACH. The first is dossier evaluation, which involves verification of ­completeness and compliance with data requirements, where registrants may be asked to provide additional information if needed. The second type is substance evaluation, which comes into play when there are concerns about potential risks to human health or the environment. In such cases, authorities have the power to request further testing or comprehensive risk assessments to address these concerns.

Authorisation and restriction

Under UA REACH, substances of very high concern (SVHCs) require special authorisation. These include Carcinogenic, Mutagenic, or ­Reprotoxic (CMR) substances, Persistent, Bioaccumulative, and Toxic (PBT) substances, as well as Very Persistent and Very Bioaccumulative (vPvB) substances. For these substances, a Toxic Chemicals Permit is mandatory. Each permit has a validity period of three years and must be issued separately for each substance and each specific use. Additionally, the regulation provides for restrictions, whereby certain substances or their uses may be restricted or prohibited altogether if they are deemed hazardous to human health or the environment.

What this means for industry

UA REACH introduces a complex compliance framework that will demand significant preparation, especially for companies with broad substance portfolios or high-volume imports. Early action is strongly advised:

• Compile a full inventory of substances manufactured or imported into Ukraine.
• Map tonnage bands to determine registration deadlines.
• Collect existing data and identify gaps requiring testing.
• Plan Only Representative appointments for non-Ukrainian suppliers.
• Engage with MEPR guidance and updates regularly.

For companies already familiar with EU REACH, the structure will feel familiar – but local administrative requirements (e. g., Ukrainian-­language forms, QES signatures) add complexity that should not be underestimated.

Key deadlines

Pre-registration (all substances): January 26, 2026

Full registration deadlines:

• 1 October  2026 – Substances ≥1000 t/a, CMRs ≥1 t/a, and aquatic toxicants ≥100 t/a
• 1 June  2028 – Substances 100–1000 t/a
• 1 March  2030 – Substances 1–100 t/a

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