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14 Feb 2025
Ukraine's New REACH Regulation Comes into Effect
Ukraine's technical regulation on chemicals, akin to the EU REACH Regulation, officially came into force on January 26, 2025. This Ukrainian regulation is based on the EU REACH Regulation (EC No 1907/2006) but differs in implementation details and timelines.
1. Scope of Application
- Ukraine REACH: Covers all chemical substances, including those used in industrial applications and everyday consumer products such as cleaning agents, paints, clothing, furniture, and electrical appliances.
- EU REACH: Also has a broad scope; however, Ukraine REACH does not differentiate between new and existing substances. All substances with an annual production or import volume of ≥1 ton must undergo pre-registration.
2. Registration Process
- Ukraine REACH: Allows substances that have already met EU REACH requirements to undergo a simplified registration process, potentially reducing data requirements or directly utilizing EU REACH registration documents.
- EU REACH: Requires a more complex registration process, including the submission of a comprehensive chemical safety report and technical documentation.
3. Pre-Registration and Registration Deadlines
- Ukraine REACH:
- Pre-registration period: January 26, 2025 – January 26, 2026.
- Registration deadlines (divided into three phases):
- October 1, 2026: Substances with an annual volume of ≥1000 tons, CMR substances (category 1A and 1B) of ≥1 ton per year, and aquatic toxic substances of ≥100 tons per year.
- June 1, 2028: Substances in the 100–1000 tons per year range.
- March 1, 2030: Substances in the 1–100 tons per year range.
- EU REACH: Deadlines vary depending on tonnage and hazard classification, generally allowing a longer timeframe for compliance.
4. Authorization and Restrictions
- Ukraine REACH: Requires authorization for 59 hazardous substances listed in Annex XIV, with a compliance deadline of June 1, 2027.
- EU REACH: Covers a broader range of substances subject to authorization and restrictions, with frequent updates to the regulated substance list.
5. Exemption Policies
- Ukraine REACH: Allows exemptions for substances used solely for scientific research and development for a period of five years, extendable for up to an additional five years.
- EU REACH: Has stricter exemption policies, mainly applicable to specific uses or low-risk substances.
6. Implementation Challenges
- Ukraine REACH: The short compliance timeframe (five years to complete most registrations) presents significant challenges for both businesses and regulatory authorities, particularly regarding data requirements and system development.
- EU REACH: Having been in place for many years, it benefits from an established regulatory framework and extensive guidance documents.
Ukraine's new REACH regulation marks a significant step towards chemical safety management in alignment with EU standards, though businesses operating in Ukraine should prepare for its unique requirements and tighter deadlines.
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