UA-REACH: What Chemical Manufacturers and Importers Need to Know

Why UA-REACH is a Topic You Can No Longer Ignore

If you manufacture, import, or use chemicals in Ukraine, the rules of the game have changed. On January 26, 2025, the Technical Regulation on the Safety of Chemical Products, known as UA-REACH, came into force. This is not a framework declaration or a "future prospect"—it is a law with specific deadlines, registration procedures, and penalties for non-compliance.

UA-REACH is part of a large-scale reform initiated by the Law of Ukraine "On Ensuring Chemical Safety and Management of Chemical Products" (No. 2804-IX dated 01.12.2022), which entered into force on June 29, 2024. The regulation was adopted by the Cabinet of Ministers Resolution No. 847 dated July 23, 2024, and transposes the requirements of the European Regulation EC 1907/2006 (REACH) into Ukrainian legislation.

SVK began preparing for UA-REACH back in 2023 when the draft law was being read in the Verkhovna Rada. Today, we have complete dossiers for 90% of the substances we use in production. This experience gave us a clear understanding: preparation requires time and a systematic approach.

For industrial chemical manufacturers, contract manufacturers of household chemicals, and raw material importers, this means one thing: you need to act now. Pre-registration is already open, and the deadlines for full registration depend on the volumes and hazard classes of the substances. Those who delay risk losing the right to supply products to the market.

What is UA-REACH in Simple Terms

UA-REACH is the Ukrainian system for the Registration, Evaluation, Authorization and Restriction of Chemicals. Essentially, it is an adaptation of the European Regulation EC 1907/2006 (REACH) to Ukrainian legislation, created as part of European integration commitments.

The basic logic is simple: "No data — no market". Every chemical substance manufactured or imported in Ukraine in a volume of 1 ton or more per year must undergo state registration. Without registration, production and circulation are prohibited.

Registration is carried out by Мінприроди (Ministry of Environmental Protection and Natural Resources of Ukraine) based on submitted applications, technical dossiers, and chemical safety reports. For each substance, you must collect and submit data on:

• substance identification (name, CAS number, molecular formula);
• physicochemical properties;
• toxicological characteristics;
• ecotoxicological data;
• risk management proposals.

If you are already familiar with EU REACH requirements for export, you may have some of this information ready. For requirements for household chemical exporters, see «Requirements for Household Chemicals for Export to the EU».

Key Differences Between UA-REACH and EU REACH

Although UA-REACH is built on the European Regulation, it is not an exact copy. There are significant differences you should understand:

A key advantage for companies working with EU-registered substances is the simplified registration procedure. If a substance is already registered with ECHA, it is sufficient to submit an application, a technical dossier, a copy of the chemical safety report, and a document confirming registration through REACH-IT. This significantly reduces costs and time.

Another important difference is that UA-REACH is being implemented under martial law. The Cabinet of Ministers has already adjusted the deadlines twice (Resolution No. 1598 dated December 5, 2025), giving businesses additional time to adapt.

Who is Obliged to Comply with UA-REACH Requirements

UA-REACH requirements apply to three categories of market participants:

1. Chemical Manufacturers

If you manufacture a chemical substance in Ukraine in a volume of ≥1 ton per year, you are obliged to register it. This applies to both pure substances and intermediates that leave the production site.

2. Importers

If you import a chemical substance (either on its own or in mixtures) in a volume of ≥1 ton per year, the responsibility for registration lies with you. This is fundamental: a European supplier is not obliged to register a substance in Ukraine. The Ukrainian importer does this.

3. Downstream Users

Companies that use registered substances in their formulas are not obliged to register them again. However, they are required to:

• use substances according to the registered exposure scenarios;
• have a Safety Data Sheet (SDS) for each substance;
• inform the supplier if the conditions of use are not described in the SDS.

It is worth noting separately: mixtures (formulas) are not registered. Registration applies to individual chemical substances. However, the mixture manufacturer must ensure that each component of their formula is registered by the respective substance manufacturer or importer. For industrial chemistry terminology and definitions of key concepts, see the «Industrial Chemistry Glossary».

Registration Deadlines: Implementation Stages

UA-REACH is implemented in stages, taking into account production/import volumes and substance hazard classes. Following the amendments by the Cabinet of Ministers Resolution No. 1598 of December 2025, the current schedule is as follows:

Pre-registration

Deadline: until January 26, 2027

Mandatory for all substances manufactured or imported in a volume of ≥1 t/year. Pre-registration involves submitting basic information about the substance: name, CAS number, estimated volumes, and the registrant's contact details. Without pre-registration, it is impossible to submit a full registration dossier.

Full Registration — by Phases

Note: deadlines gradually shift from the most hazardous and high-volume substances to lower-volume ones. This gives smaller manufacturers additional time but does not exempt them from pre-registration.

Important: new substances placed on the market for the first time after January 26, 2025, must be registered before the start of production or import. Transitional periods do not apply to them.

What Documents are Required for Registration

The registration dossier is submitted to Мінприроди and includes:

Technical Dossier (mandatory for all volumes)

1. Substance identification — IUPAC name, CAS number, molecular formula, structural formula, degree of purity, impurities.

2. Manufacturer/importer information — legal name, address, volumes, uses.

3. Classification and labeling — according to UA-CLP (analogous to EU CLP 1272/2008): hazard class, GHS pictograms, H-phrases, P-phrases.

4. Physicochemical properties — melting point, boiling point, density, solubility, vapor pressure, and others.

5. Toxicological data — acute toxicity, skin and eye irritation, sensitization, mutagenicity, carcinogenicity (based on requirements depending on tonnage).

6. Ecotoxicological data — toxicity to aquatic organisms, biodegradation, bioaccumulation.

Chemical Safety Report (CSR)

Mandatory for substances ≥10 tons per year. Includes an assessment of health and environmental impacts, exposure scenarios, and risk management measures.

For EU-Registered Substances

Simplified package: application + technical dossier + copy of the EU CSR + confirmation of registration in REACH-IT.

How to Prepare: Step-by-Step Guide

Step 1. Conduct an Inventory

Compile a complete list of chemical substances you manufacture or import. For each, record the CAS number, annual volume, hazard classification, and presence of EU registration.

Step 2. Set Priorities

Distribute substances by registration phases (see the table above). CMR substances and high-tonnage items require action first.

Step 3. Collect Existing Data

Check what data you already have: SDS from suppliers, laboratory test results, certificates. If the substance is registered in the EU, obtain confirmation from the European supplier.

Step 4. Complete Pre-registration

Submit pre-registration by January 26, 2027. The procedure is relatively simple: basic information about the substance and the registrant.

Step 5. Prepare the Technical Dossier

For full registration, you need to collect or order studies. Physicochemical, toxicological, and ecotoxicological data involve laboratory tests that take from a few weeks to several months.

Step 6. Update SDS

Safety Data Sheets must comply with UA-CLP requirements—the Ukrainian adaptation of GHS. If your SDS are compiled according to old ДСТУ standards, they must be completely reworked. Read about the connection between environmental certifications and chemical labeling in «Eco-Cleaning Products: Labeling and Certifications».

Step 7. Appoint a Responsible Person

UA-REACH requires a contact person responsible for registration and communication with Мінприроди. For small companies, this can be an external consultant. A useful resource to start with is the ECHA Guidance on Registration, which is largely applicable to UA-REACH as well.

As Anna Khomenko notes: "According to our observations, the greatest difficulty for small and medium-sized enterprises is not the registration itself, but the collection of toxicological data. For many substances, this data simply does not exist in Ukrainian, and it must either be translated from EU dossiers or new studies must be ordered. We have walked this path and know where to look."

Liability for Non-Compliance

The Law "On Ensuring Chemical Safety and Management of Chemical Products" provides for disciplinary, administrative, civil, and criminal liability for violating chemical safety requirements.

Specific consequences for business:

• Circulation ban — unregistered substances cannot be manufactured, imported, or supplied to the market. This means a halt in production.
• Activity restriction — by court decision, a full or partial shutdown of the enterprise, individual production facilities, or production units is possible.
• Damage compensation — damage caused as a result of violating requirements is subject to full compensation.
• Market access ban — products that do not comply with the technical regulation cannot be placed on the market.

For export-oriented companies, the consequences are twofold: violating UA-REACH jeopardizes both domestic and foreign sales. European partners increasingly request confirmation of compliance with the supplier's national legislation. Read about the impact of the PFAS ban on industrial chemistry in «PFAS Ban in the EU».

FAQ

Does UA-REACH apply to finished mixtures (household chemicals, paints, lubricants)?

Mixtures as such are not registered. Individual chemical substances within their composition are subject to registration. However, the mixture manufacturer is obliged to ensure that each component of their formula is registered by the respective manufacturer or importer.

If our raw materials are imported from the EU and already have EU REACH registration, do we need to register them in Ukraine?

Yes, you do. EU REACH registration does not replace the Ukrainian one. However, the procedure will be simplified: it is sufficient to submit an application, a technical dossier, a copy of the CSR, and confirmation of registration through REACH-IT. This significantly reduces preparation time and costs.

What are the deadlines for pre-registration?

Pre-registration is open from January 26, 2025, and will last until January 26, 2027. Without pre-registration, you will not be able to use the transitional periods and will be obliged to register the substance before the start of production or import.

What should a small enterprise do if it uses 5–10 substances in volumes up to 10 tons?

For substances of 1–100 t/year, the full registration deadline is March 1, 2031. However, pre-registration must be completed by January 26, 2027. Start with an inventory: compile a list of substances, collect SDS from suppliers, and determine what data is missing. For small volumes, the technical dossier will be simpler (fewer requirements for toxicological tests).

How SVK Helps with Compliance

As an industrial chemical manufacturer, SVK works with regulatory requirements every day. We understand that for many companies, UA-REACH is a new and unfamiliar process. Here is how we help:

Formula documentation. Every SVK formula is accompanied by a complete package of technical documentation: specifications, formulations, and component data. When developing contract formulas, we consider UA-REACH and UA-CLP requirements at the design stage.

SDS support. Our laboratory and technical department assist with compiling and updating Safety Data Sheets in accordance with UA-CLP requirements. We work with the 16-section SDS format, including GHS classification, H/P-phrases, and exposure scenarios.

Laboratory testing. SVK has its own laboratory for conducting physicochemical tests. For toxicological and ecotoxicological studies, we partner with accredited laboratories.

Regulatory consulting. If you plan to bring new chemical products to the market or transfer production to a contract basis, we will help assess regulatory requirements at the development stage, not after launch.

📩 Contact us for a free consultation on UA-REACH compliance for your production.

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Read Also

• «Requirements for Household Chemicals for Export to the EU» — a complete regulatory guide on EC 648/2004, CLP, and REACH for exporters
• «PFAS Ban in the EU» — how the ban on "forever chemicals" affects manufacturers
• «Eco-Cleaning Products: Labeling and Certifications» — EU Ecolabel, Nordic Swan, and other eco-schemes
• «Industrial Chemistry Glossary» — terminology and definitions from A to Z