Ukraine REACH Compliance Services

Written By Guest User

Ukraine has introduced its own chemical regulation, commonly referred to as UA-REACH, modelled closely on the EU’s REACH framework. This regulation requires manufacturers, importers and downstream users placing substances on the Ukrainian market at or above one tonne per year to register those substances, submit pre-registrations during the transition period, and comply with the Ukrainian classification, labelling and packaging requirements (UA-CLP). Non-Ukrainian companies may appoint an Authorised Representative (Only Representative) in Ukraine to maintain market access.

At Yordas, we offer end-to-end support for Ukraine REACH compliance, covering gap analyses, preliminary state registration, full registration, Only Representative services, SDS authoring in Ukrainian, UA-CLP submissions and ongoing regulatory monitoring to safeguard your supply chain and access to the Ukrainian market.

Key Deadlines and Obligations

The Ukrainian authorities have released both final and draft extension dates for UA-REACH. It is critical to monitor developments closely; we can help you interpret draft versus final requirements and plan accordingly. The key obligations include:

Pre-registration:
26 January 2025 – 26 January 2026: Required for all substances already on the Ukrainian market.

Full registration deadlines:

  • 26 January 2026: CMR substances ≥1 t/y and substances very toxic to aquatic organisms ≥100 t/y.

  • 1 October 2026: Substances ≥1,000 t/y.

  • 1 June 2028: Substances 100-1,000 t/y.

  • 1 March 2030: Substances 1-100 t/y.

Please note: Draft government changes may extend some of these dates. Please contact us for the latest update.

UA-CLP (Classification, Labelling and Packaging):  All hazardous substances placed on the Ukrainian market must be classified, labelled (in Ukrainian) and notified under UA-CLP requirements.

Only Representative:  Non-Ukrainian manufacturers may appoint an Only Representative based in Ukraine to fulfil compliance obligations, enabling continued market access without a Ukrainian local entity.

Additionally:

  • Downstream user obligations (e.g., using registered substances within the supply chain) should be assessed.

  • Importer obligations (for companies placing substance(s) or mixtures into Ukraine) must be understood and managed.

  • Product categories such as plastics/additives, biocides, waste-derived materials may carry specific additional obligations under UA-REACH and related legislation.

Our Services

We offer a comprehensive suite of services to support your compliance with UA-REACH and related Ukrainian chemical regulations:

  • Gap analysis & strategy development: We map your chemical portfolio against UA-REACH obligations (pre-registration, registration, UA-CLP, downstream users/importers) and propose a tailored strategy.

  • Pre-registration support: We assist with the preparation and submission of preliminary notifications for substances already on the Ukrainian market within the transition period.

  • Full registration and dossier preparation: Leveraging existing data (where available), we prepare registration dossiers in compliance with UA-REACH and manage submission.

  • Only Representative services via Yordas LLC (Ukraine): We act as your local compliance partner in Ukraine, managing regulatory interface and enabling smoother market access for non-Ukrainian manufacturers.

  • UA-CLP – Classification, Labelling & Packaging: We prepare compliant labels (in Ukrainian) and notifications under the Ukrainian CLP regime.

  • Safety Data Sheets (SDS) in Ukrainian: We produce or translate SDSs into Ukrainian, ensuring full hazard communication compliance.

  • Authority liaison & submission management: We provide a single point of contact within Ukraine, manage submission workflows and regulatory correspondence.

  • Ongoing monitoring & updates: We keep you informed of regulatory changes (including draft extensions and evolving guidance) and help you maintain compliance over time.

GB-based Downstream users and Distributors who rely on their supplier's EU-REACH Registrations may find their role in the supply chain has shifted to Importer. They may submit a basic Downstream User Import Notification (DUIN) for their substances, allowing for the Registrations to be deferred until a later date.

EU companies that need to maintain access to the GB market must do so via a GB subsidiary or appoint an Only Representative. Grandfathering will not be an option here, so to comply with UK-REACH they may need to submit a DUIN or potentially use the New Registration of Existing Substance (NRES) option, depending on their circumstances.

Why Choose Yordas

Local presence: We have established a Ukrainian entity (Yordas LLC) offering direct in-country representation and regulatory interface in Ukraine.

  • Global expertise: With broad experience across EU REACH, UK REACH, and other international frameworks, we ensure a harmonised and strategic approach to your chemical compliance.

  • Integrated scientific and regulatory capability: Our team includes in-house toxicologists, exposure assessors and data analysts, enabling us to deliver technically robust solutions aligned to your business goals.

  • Client-focused delivery: We prioritise your business continuity and market access. Our compliance solutions are practical, aligned with your supply chain and fit within your commercial timelines.

  • Proactive change management: With emerging draft deadline extensions and evolving regulatory expectations in Ukraine, we help you stay ahead of risk and prepare for future obligations.

Next Steps

If your organisation is placing substances or mixtures on the Ukrainian market or is considering appointing an Only Representative in Ukraine, Yordas can support you every step of the way—from initial portfolio assessment to full registration and ongoing compliance.

Contact us today via our enquiry form to discuss your specific requirements and safeguard your access to the Ukrainian market.

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