REGULATION & COMPLIANCE
Category |
Criteria |
Multiplying factor |
Tonnage band( tonnes / year |
1-10 |
2.5 |
|
10-100 |
5 |
|
100-1,000 |
25 |
|
> 1,000 |
50 |
Information providing type |
Individual |
2 |
|
Joint |
1 |
Procedure for submission |
State registration |
2 |
|
Intermediate |
0.5 |
|
EU-registered |
0.5 |
Company size |
Micro |
0.25 |
Small 0.5 Medium 0.75 Large 1
Table 2- Factors in calculation of UA REACH registration fee the sunset date is 1 June 2027 for all substances. The only exemption applies to DEHP in medical devices where these dates are 1 January 2029 and 1 July 2030 respectively.
Both annexes will be part of an online system, the so-called State Register of Chemicals Substances, which shall contain several lists, such as all the substances imported or manufactured by legal entities in Ukraine at > 1 tonne / year, meaning all( pre)-registered substances.
It will also contain the list of toxic substances, which is something newly added by Ukraine government. Toxic substances will be determined after the registration according to UA REACH and notification according to UA CLP. Toxic substances will be those classified as toxic Category 1 to 3, STOT SE Category 1 and 2 and STOT RE Category 1 and 2. For toxic substances a permit is required.
Fees are regulated in the Law on Chemicals. The fee for a UA REACH registration will be calculated based on the subsistence minimum multiplied by several factors: the tonnage band, the type of submission( individual or joint), the type of application( state registration, intermediate or simplified registration for EU registrants) and the company size( Table 2). Based on the current subsistence minimum, the fees for a large company range from approximately € 100 to a maximum of € 7,000.
UA CLP
UA CLP implements GHS in Ukraine based on the 7th revision of GHS as in the EU CLP. All annexes have been copied as well and the mandatory classifications of Annex VI are based on the 17th ATP. Like UA REACH, UA CLP has a translation table added that makes it easier to find articles of EU CLP in UA CLP and to identify those that have been added by the Ukrainian government.
With the implementation of GHS, Ukraine introduced an obligation for importers and manufacturers to notify all hazardous substances they handle. This so-called CLP Notification was originally due by 15 November 2025, but will probably be postponed by the draft resolution to 15 May 2026. Unlike in UA REACH, the obligation to submit CLP notifications cannot be delegated to an OR, as the OR mechanism is not part of UA CLP( similar to EU CLP).
Summary
Ukrainian chemical legislation closely mirrors EU REACH and CLP, with key deviations primarily related to the absence of a robust IT infrastructure and ongoing regulatory ambiguities. The key recommendation is to complete pre-registration as soon as possible to secure the associated grace period. As a second step it is necessary to identify potential co-registrants after the preregistration. It is also essential to monitor developments in Ukraine, as regulatory timelines and digital tools may evolve in the coming months. ●
J j
Wiebke Sossinka
SENIOR REGULATORY AFFAIRS MANAGER / CHEMICALS & PRODUCT SAFETY
KNOELL wsossinka @ knoell. com www. knoell. com
58 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981