Chemical safety in Ukraine: key regulatory updates

The Ministry of Environment Protection and Natural Resources of Ukraine (MEPR) have introduced a comprehensive regulatory framework for chemicals, taking a significant step towards aligning with international standards, such as EU REACH and CLP. Preparing for and adapting to these changes will be crucial for organisations to ensure compliance and maintain market access.

Under these regulations, manufacturers, importers, and distributors are required to provide registrations for substances imported in quantities of one tonne or more per year. They are also required to follow the hazard classification and labelling protocols and update their associated Safety Data Sheets (SDS).

Ukraine REACH

The transition period for Ukraine REACH began on 26 January 2025, introducing a structured framework for chemical substance registrations. Similar to EU and UK REACH regulations, substances imported into Ukraine in quantities of one tonne per year or more must be registered. 

The pre-registration and registration deadlines are outlined below: 

To comply with Ukraine REACH, businesses not based in the country must appoint an Authorised Representative (functionally similar to ‘Only Representative’ under EU REACH) to manage the registration process and liaise with Ukrainian authorities on their behalf. Communication and dossier submission will likely be in Ukrainian.

The pre-registration period will allow companies to identify their obligations, prepare for full registration and ensure they have access to the required data to initiate collaborations. The registration process will involve the submission of a technical dossier with detailed substance data. Additionally, substances exceeding 10 tonnes per year will also require submission of a Chemical Safety Report (CSR). The CSR must include hazard assessments, exposure scenarios and risk management measures, ensuring compliance with Ukrainian regulatory standards for chemical safety.

For substances already registered under EU REACH, Ukraine REACH offers a simplified registration process. This will involve fewer dossier requirements, making it easier for businesses to transition their existing compliance into the Ukraine framework while maintaining market access. 

As Ukraine’s chemical regulations align with global standards, companies will have to adapt to the new requirements, and early preparation – including appointing an Authorised Representative – will be essential to ensure compliance.

Safety Data Sheets (SDS)

Under Ukraine REACH (UA REACH), and as with EU REACH, SDS will need to follow the 16-point format, including exposure scenarios when required. All SDSs and extended SDS (eSDS) must be prepared in the Ukrainian language to ensure compliance with local requirements. Compliant SDS will be required for hazardous substances and mixtures, in accordance with Annex II of the regulation.

If chemicals have been placed on the Ukrainian market prior to the inception of UA REACH, a 12-month transition period applies. However, immediate compliance is required for any chemicals placed on the market for the first time after January 26th, 2025.

When creating an SDS for a mixture, an alternative name may be used for certain substances if it meets the relevant criteria set out in Part A of Annex I of the regulation. The alternative name of the chemical must be approved by the Cabinet of Ministers of Ukraine and notified to the Ministry of Environment through Registration of Notices of Use process.

Ukraine Classification, Labelling and Packaging (CLP)

Labels will be required to be applied in accordance with Ukraine CLP (UA-CLP), which came into force on 15 November 2024. Products already placed on the market have until 15 November 2025 to comply. For the new hazard classes adopted by the EU for endocrine disruptors and persistent chemicals (chapters 3.11, 4.2, 4.3, 4.4,) however, compliance will not be required until later dates, as in EU CLP.

This structured approach ensures hazard information is communicated clearly and consistently, facilitating compliance with Ukraine REACH while meeting international regulatory standards.

Poison Centres

A significant aspect of Ukraine CLP is the additional requirement for Poison Centre Notifications (PCNs), which will apply from January 1st, 2025. These notifications must be submitted in Ukrainian.

As in the EU, the regulation includes requirements for manufacturers, importers, and downstream users to submit detailed information on chemical mixtures including their composition, associated hazards, and toxicological data. Specific transition periods apply, with different deadlines for general, professional, and industrial use chemicals (2025, 2026, and 2027, respectively).

A key requirement is the provision of Unique Identifier Formula (UIF): an alphanumeric code linking a mixture to the provided information. This will streamline the notification process, especially for companies with multiple mixtures in their product portfolio.

The necessary IT infrastructure and databases to hold these classification and labelling (C&L) and Poison Centre notifications are still under development. Ricardo’s Poison Centre team is closely monitoring the development of the IT infrastructure for submission and will provide support to our customers as the systems for submitting notifications become available.

Emergency Response

UA REACH includes the provision of an Emergency Response Telephone number in Section 1 of the SDS. This general requirement ensures there is a point of contact capable of providing immediate support in the event of an emergency. Whilst it is important to include a Poison Centre telephone number for cases of poisoning, best practice requires consideration of all potential incidents, including spillages and fires. This requires an emergency response telephone number capable of supporting such events in the local language, Ukrainian.

Learn more about emergency response >