Ukraine REACH & CLP: Current status
Wiebke Sossinka of Knoell provides an overview of the current status of Ukrainian REACH and CLP regulations and shares insights into the practical implementation challenges
Figure 1 – Hierarchy of legislation
Law on Chemical Safety( December 2022)
Approval of Technical Regulation( May 2024) |
Approval of Technical Regulation( July 2024) |
Approval of Procedures( August 2024) |
Other regulations to come |
Technical Regulations for the Classification, Labelling and Packaging of Chemical Products |
Technical Regulations on the Safety of Chemical Products |
State Register of Chemical Substances |
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As Ukraine aims to join the EU, its legislators are progressively aligning national laws with EU legislation, in line with the obligations under the EU- Ukraine Association Agreement. This has necessitated a comprehensive update to its chemical regulations. Step by step, the Ukrainian government has released new laws and regulations for this purpose.
The first step in this process was the adoption of the Law of Ukraine on Ensuring Chemical Safety and the Management of Chemical Products, published on 1 December 2022( Law on Chemical Safety). This law serves as the overarching legal framework for chemicals in Ukraine and forms the basis for the implementation of Ukrainian REACH( UA REACH) and Classification, Labelling & Packaging( UA CLP) regulations, which closely mirror their EU counterparts.
The majority of the Law on Chemical Safety came into force on 29 June 2024. As in many other regions the Law does not apply to substances regulated already elsewhere. In Ukraine, these include:
• Active ingredients of pharmaceutical & medicinal products;
• Narcotic drugs, psychotropic substances, their analogues & precursors
• Pesticides & agrochemicals
• Biocides, disinfectants
• Tobacco products, nicotinecontaining products
• Final cosmetic products It is important to note that the definition of a biocide in Ukraine is narrower than in the EU at this stage. The current regulation focuses on disinfectants.
Ukraine intends to align its regulation with the EU and it has already drafted the UA Biocidal Products Regulation( UA BPR), a regulation that would much more be in line with the EU BPR. This was published in early August 2025, followed by a 30-day public consultation period. As yet, no updates regarding the final publication have been published.
UA CLP was published on 10 May 2024 and entered into force six months later. Some provisions took effect on 1 January 2025 and an additional transition period has been provided for the reclassification and relabelling of substances and mixtures. UA REACH was published on 23 July 2024, entering into force immediately.
As the general requirements are so close to those of EU CLP and REACH the dates where specific steps have to be done are of most relevance. It has to be noted, that currently( as
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