Overview
Recently, the Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR) officially released the pre-registration template for Ukraine REACH. This long-awaited development marks a critical milestone in the practical implementation of Ukraine REACH. Although the regulation has been in effect for nearly four months, incomplete supporting procedures had hindered companies from advancing compliance efforts. Now, companies can finally begin standardized pre-registration for chemicals placed on the Ukrainian market. According to the transitional provisions of the regulation, manufacturers, importers, and authorized representatives (for non-Ukrainian manufacturers) must pre-register chemical substances (excluding exempted substances) with an annual volume ≥1 ton to qualify for the staggered registration deadlines. The pre-registration window is set from January 26, 2025, to January 26, 2026.
Pre-Registration Requirements
To ensure uniformity and structure, MEPR has released an Excel-based standardized template and accompanying guidelines to unify submission rules and formats. Key points for companies during pre-registration:
The form must be completed in Ukrainian.
Documents must be electronically signed by an authorized company representative (e.g., a director) using a Qualified Electronic Signature (QES).
Submission materials must include the completed template, supporting documents, and a Letter of Appointment for the Authorized Representative (if applicable).
All materials must be sent to the official designated email address.
Similar to EU REACH, non-Ukrainian manufacturers may appoint an Authorized Representative to handle pre-registration and subsequent formal registration, provided authorization proof is submitted.
Challenges in Formal Registration
While the release of the pre-registration template advances Ukraine REACH implementation, challenges for formal registration are just beginning. Under tight deadlines, critical unresolved issues remain, such as:
Development status of the IT system for formal registration submissions.
Whether IUCLID (used for EU REACH dossiers) will be adopted.
Procedures for Lead Registrant elections and data-sharing mechanisms.
Implementation details for "simplified registration".
Preparation time for formal registration is limited, especially for high-hazard substances. The first deadline for CMR substances (Category 1A/1B) and aquatic toxic substances (Acute/Chronic Category 1) with annual volumes ≥1 ton or ≥100 tons, respectively, is January 26, 2026. Ensuring the smooth progress of formal registration due to imperfections in the supporting procedures will be a huge challenge for companies. However, if no immediate action is taken, it will be even more difficult to move forward in the future.
Formal Registration Deadlines
January 26, 2026: CMR substances (Cat. 1A/1B) ≥1 ton/year; aquatic toxicants (Acute/Chronic Cat. 1) ≥100 tons/year.
October 1, 2026: Substances ≥1,000 tons/year.
June 1, 2028: Substances 100–1,000 tons/year.
March 1, 2030: Substances 1–100 tons/year.
While gaps between policy and implementation persist, the release of the pre-registration template underscores Ukraine’s commitment to advancing chemical regulations and aligning with EU chemical safety standards. REACH24H advises companies with Ukrainian market interests to initiate pre-registration immediately, prepare for high-hazard substance registrations, and closely monitor MEPR’s ongoing policy updates.
