The Government of Ukraine continues to advance the alignment of its chemical compliance framework with European Union requirements. Recognising the practical challenges faced by industry in meeting the originally established transitional deadlines, the Ministry of Economy and the Ministry of Environment have published draft amendments to two key Cabinet of Ministers’ resolutions:

• Resolution No. 539 of 10 May 2024 – on the classification, labelling, and packaging of chemical products

• Resolution No. 847 of 23 July 2024 – on the safety of chemical products

The purpose of these amendments is to provide companies with sufficient time to comply with the requirements of UA-REACH and UA-CLP.

Key proposed changes to transitional periods

The draft amendments introduce the following revised compliance deadlines:

• Preliminary registrations: until 26 January 2027

• CMR category 1A or 1B substances ≥ 1 tonne/year and substances very toxic to the aquatic environment ≥ 100 tonnes/year: until 1 October 2028

• Substances > 1,000 tonnes/year: until 1 October 2029

• Substances 100–1,000 tonnes/year: until 1 June 2031

• Substances 1–100 tonnes/year: until 1 March 2033

• CLP notifications: until 15 May 2026

The draft amendments have been published for public consultation on the Ministry’s website (me.gov.ua). The consultation period runs until November 2025.

What this means for businesses

In addition to the opportunity to submit comments during the consultation process, the proposed extensions provide companies with more time to prepare for the implementation of REACH and CLP requirements for products placed on the Ukrainian market.

At the same time, it is a clear signal that the Ukrainian Government is closely monitoring the progress of implementation, and companies should not postpone preparations for compiling and updating the required compliance documentation for the Ukrainian market.