UA-CLP and UA-REACH: What the Ukrainian Chemical Industry Must Do by the End of 2026 and January 2027
- ETS Certification
- Jun 3
- 4 min read
Ukraine continues to steadily implement a modern chemical safety management system, fully harmonised with stringent European approaches. For domestic companies, this represents a significant transition to a new regulatory framework.
Today, companies operating with chemical products such as detergents, cosmetic products, construction paints, solvents, aerosol dispensers, lubricants, fertilizers, and others are directly facing the new requirements of the Ukrainian REACH and CLP regulations.
Manufacturers, importers, and suppliers of such products must already take into account the provisions of the basic Law of Ukraine “On Chemical Safety and Management of Chemical Products,”(Закону України «Про забезпечення хімічної безпеки та управління хімічною продукцією») as well as the secondary legislation adopted for its implementation, including, а :
the Technical Regulation on the Safety of Chemical Products (UA-REACH) - Технічного регламенту щодо безпечності хімічної продукції (UA-REACH)
the Technical Regulation on Classification, Labelling and Packaging of Chemical Products (UA-CLP) - Технічного регламенту щодо класифікації, маркування та пакування хімічної продукції (UA-CLP).
For many types of chemical products falling within the scope of these Technical Regulations, it is necessary to ensure the availability of an up-to-date Safety Data Sheet (SDS) in the Ukrainian language, comply with the requirements for prior hazard communication of chemical substances, and timely perform pre-registration of substances where required by legislation.
Compliance with these procedures is critical for all business entities manufacturing, importing, or placing on the market chemical raw materials and finished products in Ukraine.
Why have REACH and CLP become so important?
The Technical Regulations adopted in Ukraine are fully harmonised with the European REACH and CLP regulations, which form the cornerstone of strict control over the circulation of chemical substances both in Ukraine and in the European Union.
UA-REACH regulates the registration, evaluation, and conditions for the safe use of chemical substances at the state level.
UA-CLP establishes clear rules for hazard classification, labelling, and packaging of products to ensure their safe placement on the market.
Prior notification of chemical hazards (under UA-CLP)
Prior notification of hazard information (notification) is a mandatory procedure for submitting data on the classification and labelling of a hazardous substance in accordance with the requirements of UA-CLP.
According to paragraph 129 of the Technical Regulation on Classification, Labelling and Packaging of Chemical Products (No. 539), the relevant notification must be submitted within one calendar month from the date of the first placing of the hazardous substance on the Ukrainian market.
⏳ Critical deadline: By 6 December 2026, businesses must complete the submission of classification and labelling notifications for all hazardous substances already placed on the market.
Pre-registration of substances (under UA-REACH)
Pre-registration is a strategic stage in the implementation of the UA-REACH system. It allows companies to legally continue placing substances on the Ukrainian market until the completion of the full and more complex state registration procedure.
To successfully complete pre-registration, businesses must prepare the following information:
substance identification data;
details of the manufacturer or importer;
total production or import volumes;
hazard classification of the substance;
up-to-date information on safe use conditions.
⏳ Critical deadline: Pre-registration of substances under the basic Law on Chemical Safety must be completed by 26 January 2027.
Which businesses and product types are most critically affected?
Household and professional chemicals
The new requirements directly affect laundry detergents, liquid cleaning agents, capsules, disinfectants, antiseptics, and automotive chemicals, including windscreen washer fluids and antifreeze products. Importers of finished foreign products are required to complete notification in Ukraine even if EU REACH compliance certificates are already available. Domestic manufacturers who formulate products under their own brand bear full responsibility for registration as well.
Cosmetics and perfumery
The scope includes both finished cosmetic products containing hazardous substances and chemical raw materials used in their production—such as surfactants, fragrances, and preservatives. Ukrainian cosmetic manufacturers, as well as importers of foreign raw materials, must ensure full regulatory compliance of all substances used in formulations.
Construction sector
The rules apply to construction paints, varnishes, enamels, solvents, primers, adhesives, sealants, and ready-to-use mixtures containing specific chemical additives. This concerns not only retailers, but also industrial enterprises that import such substances for use in their own production processes.
Aerosol products
Registration and hazard communication requirements are mandatory for all products supplied in aerosol packaging. This includes both household products such as air fresheners or deodorants, as well as technical sprays used for industrial or specialized applications.
Automotive sector
The new legislation regulates the placing on the market of technical oils, lubricants, brake fluids, coolant fluids, and other operational liquids. Compliance responsibility lies with importers, large distributors, and companies engaged in repackaging or private-label distribution of these products.
Agricultural sector
The regulation is critically important for manufacturers and importers of mineral, liquid, and compound fertilizers, as well as plant protection products, pesticides, herbicides, and plant growth regulators. Both suppliers of finished imported agrochemicals and local companies formulating mixtures domestically are required to notify hazards and register substances in accordance with the applicable legislation.
Why preparation should not be postponed until the last month
Experience from the European Union clearly shows that, as transitional deadlines approach, national registration systems and independent experts face significant overload.
Careful review of Safety Data Sheets (SDS), verification of correct classification, collection of accurate volume data, and preparation of technical dossiers require substantial time and resources. The earlier your company begins this process, the lower the risk of sudden disruptions in imports or sales due to regulatory non-compliance or documentation errors.
How can Eurotechstandard help?
The experts of Eurotechstandard LLC (Conformity Assessment Body) have the necessary practical experience and provide daily support to Ukrainian businesses in navigating complex chemical compliance requirements.
We provide:
clear identification of your company’s obligations under the updated legislation;
audit and analysis of chemical substances subject to mandatory pre-registration;
classification of products in accordance with UA-CLP standards;
preparation, detailed completion, and submission of notifications on classification and labelling;
full support of the pre-registration procedure within state registries.
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