REGULATION & COMPLIANCE of November 2025) a draft is under public consultation to postpone the deadlines for UA REACH and UA CLP. If the draft is approved as proposed the deadlines will be shifted, as shown in Figure 1.
Requirements under UA REACH
The Ukrainian version of REACH is very close to EU REACH, with some adoptions to the legal system in the Ukraine and the administrative structure. A comparison table can be found in Annex XVIII of the Ukraine REACH implementation, showing EU articles in the Ukraine version and the paragraphs of UA REACH that are not in EU REACH.
As under EU REACH, UA REACH requires as a first step the preliminary registration( pre-registration). An existing pre-registration grants the holder a grace period until the final registration is due. Initially, the preregistration was possible until 26 January 2026, but this deadline is likely to be postponed for one year.
After the pre-registration the Ministry will publish a list of all preregistered substances. Potential registrants must then establish a substance information exchange forum( SIEF). Unlike in the EU, the Ukrainian ministry has not yet implemented an electronic platform to facilitate connections among preregistrants of the same substance. Thus, registrants have to find a way to connect to each other on their own.
Non-Ukraine companies can appoint an Only Representative( OR), as in the EU, to submit( pre-) registrations on their behalf to protect their confidential business information( CBI) and as a service to Ukrainian importers. The OR has to be located in Ukraine and can either be a service provider, a legal entity acting for all non-Ukraine legal entities of the same company or a trustworthy importer.
For the full registration, a joint registration is foreseen, with one applicant being the lead registrant( LR) and all others joining afterwards. There will be a simplified registration for those who have already registered in the EU. What that means for joint registrations is currently unclear, for instance, can companies join a joint registration that has been submitted as a simplified registration, if they do not hold an EU registration?
Several uncertainties remain regarding practical implementation. For example, earlier this year the ministry indicated that all submissions must be in Ukrainian. If that is required, a huge effort will have to be made to translate all the EU REACH dossiers.
Another point is that no electronic system for submission of the applications has been established. The current pre-registration is done via MS Excel sheets that have to be sent by email to the ministry( or as printout paper versions by normal mail).
Lately, rumours suggest that Ukraine may adopt IUCLID, although no official confirmation has been released to date. This would significantly ease the effort for EU registrants, especially if it includes the use of English instead of Ukrainian.
However, still there are challenges to face, mainly in cases where the EU LR is not registering in the Ukraine. In this case, an agreement has to be found to use the data of the EU lead dossier in the Ukrainian dossier. Here the help of consultants like Knoell can be needed to act as a trustee between the involved parties.
Annexes to UA REACH & fees
Ukraine has largely adopted the annexes of EU REACH. However, some notable differences exist.
For Annex XVII, the last entry is number 78 on synthetic polymer microparticles. Furthermore, some dates have been adjusted to fit to the Ukrainian timelines. Thus, if it is known that a substance is on the EU Annex XVII up to entry 78, it is on the Ukrainian Annex XVII as well, but other reviews or dates of coming into force may apply. This has to be checked for each substance separately.
Annex XIV is also a copy of the EU Annex and contains all 59 entries as listed in the EU. The deadline to submit an application for authorisation is 1 April 2027 and
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