November 6, 2026 by Alex Coxon & Gulay Cote
The Ukrainian authorities published draft legislation on the 5th November 2026 proposing postponement of the Preliminary State Registration and CLP Notification deadlines. The proposed changes are as follows:
Preliminary State Registration Deadline: 26 January 2027 → 26 July 2028
CLP Notification Deadline: 6 December 2026 → 5 December 2028
The Ministry of Economy and Environment of Ukraine has, in parallel, issued new submission forms for use during Preliminary State Registration as well as other critical updates regarding chemical safety compliance under Ukraine REACH and CLP. Stakeholders are strongly advised to review the updated official templates and prepare for possible changes to upcoming regulatory milestones.
Proposed Deadline Extensions & Ongoing Public Consultation
The Ministry of Economy and Environment of Ukraine has launched a formal public consultation proposing amendments to Cabinet Resolutions No. 539 (Ukraine CLP) and No. 847 (Ukraine REACH).
Draft Resolutions
The draft resolutions seek full alignment with EU CLP (1272/2008) and EU REACH (1907/2006) standards. Given current technical infrastructure gaps, including the establishment of poison control centers and Unified Formula Identifier (UFI) management systems, the Ministry is responding to calls from industry stakeholders for a postponement of submission deadlines to prevent market disruption. The draft seeks to clarify technical provisions based on domestic capabilities while updating institutional references across the regulatory framework.
The draft legal text, explanatory notes, and regulatory comparison tables are available for review on the Ministry’s Official Consultation Portal.
Key Takeaway: This document remains a draft proposal. It has not yet been enacted by the Cabinet of Ministers and holds no binding legal authority until formal approval and publication in the official gazette. Therefore, the current deadlines still apply.
Next Steps & Action Plan
Public Consultation Window: Stakeholders may submit formal feedback and policy proposals within one month of publication via the Ministry’s Public Discussion Platform.
Industry Engagement: Yordas Group continues to engage with the industry and regulatory bodies to submit technical feedback on behalf of the chemical industry.
Upcoming Updates: Look out for our upcoming detailed briefing paper covering the strategic implications of the proposed transitional deadlines.
Updated Submission Forms & Administrative Changes
Alignment with Statutory Timelines: The republished Preliminary State Registration forms directly reflect current statutory deadlines, incorporating adjustments under Cabinet Resolution No. 1598.
Updated Competent Authority Contact Details: Competent Authority email addresses have been updated. Submissions sent to legacy or outdated administrative addresses risk rejection or processing delays.
Official Download Portal: Finalized submission templates and guidance documentation are hosted on the Ministry of Economy’s Technical Regulation Portal-UA REACH and Ministry of Economy’s Technical Regulation Portal-UA CLP.
Important Reminder: Because outdated application forms remain accessible on the former Ministry website, ensure your team downloads submission templates exclusively from the active portal linked above.
Questions?
With an established entity in Ukraine and direct engagement with the regulatory authorities, Yordas supports companies through the full registration process, from portfolio scoping and data gap analysis to submission.
If you would like to discuss your position or validate your approach, contact Yordas to continue the conversation.
Alex Coxon | Managing Consultant: Chemical Regulatory
Dr Alexander Coxon is a Managing Consultant with 8+ years of industry and consultancy experience ensuring the regulatory compliance of chemical products, with expertise in global product stewardship, regulatory reporting and REACH-like regulations. At Yordas, his primary focus is on developing strategies and leading the implementation of projects that help clients address chemical regulations on a global scale. By providing Only Representative services and broader regulatory support, he enables companies to navigate diverse international requirements while maintaining compliance and operational efficiency. Prior to working in the regulatory sector, Dr Coxon completed a Ph.D. in Inorganic Chemistry at the University of Bath before entering the lubricant industry to lead research and development projects bringing novel chemistries to market.
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