Ukraine REACH Pre-Registration Begins: What Global Businesses Must Know

In January 2025, Ukraine officially launched its national REACH-style regulation for the management of chemicals, marking a significant step toward aligning with global standards on chemical safety and environmental protection. 

The Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR) has now opened the pre-registration phase, providing companies with a one-year window—from January 26, 2025, to January 26, 2026—to begin preparing for full compliance.

This development is particularly important for manufacturers, importers, and Only Representatives (ORs) operating in Ukraine or placing substances on the Ukrainian market.

With a framework modeled closely after the EU REACH regulation, Ukraine REACH introduces phased compliance obligations based on substance volume and hazard classification.

Understanding Ukraine REACH

The Ukrainian Technical Regulation on chemical safety introduces requirements for the registration, evaluation, and authorization of chemical substances to ensure a high level of protection for human health and the environment. Companies placing chemical substances on the Ukrainian market in volumes of 1 tonne or more per year must either register the substance themselves or appoint an Only Representative to do so on their behalf.

Pre-registration is a mandatory precursor to full registration, enabling companies to benefit from staggered registration deadlines that extend through to 2030 depending on substance type and volume. Failure to pre-register during this initial phase may result in the loss of transitional provisions and lead to immediate registration obligations, or restrictions on market access.

Pre-Registration Requirements

The MEPR has published an official Excel-based pre-registration template, which must be completed in Ukrainian for each individual substance. Key submission requirements include:

• One form per substance
  
  
• Completion of all required fields in Ukrainian
  
  
• Electronic signature using a Qualified Electronic Signature (QES)
  
  
• Submission by email to reach@mepr.gov.ua
  
  
• Supporting documentation including safety data sheets, and where applicable, an Only Representative appointment letter
  
  

The template is currently available only in Ukrainian and must be submitted electronically in accordance with MEPR’s guidance.

Registration Deadlines Following Pre-Registration

By completing pre-registration within the allowed timeframe, companies can align with the following phased registration deadlines:

• Carcinogenic, mutagenic, or reprotoxic (CMR) substances in Categories 1A and 1B (≥1 t/a)
• Substances very toxic to aquatic organisms (≥100 t/a)

• Substances manufactured or imported in quantities ≥1,000 t/a

• Substances manufactured or imported in quantities between 100 and 1,000 t/a

• Substances manufactured or imported in quantities between 1 and 100 t/a

Companies that do not complete pre-registration during the designated window will not be eligible for these transitional timelines and may be subject to immediate registration requirements.

Implications for Non-Ukrainian Companies

Manufacturers located outside Ukraine must appoint an Only Representative established in Ukraine to fulfill their obligations under Ukraine REACH. The OR will be responsible for managing the pre-registration and subsequent registration on behalf of non-resident entities. Proof of appointment must be included in the pre-registration submission.

For companies that have already registered substances under EU REACH, a simplified registration route may be available, although it will still require documentation in Ukrainian and compliance with Ukraine-specific administrative requirements.

How GoCompliance Can Support Your Business

As global product compliance becomes increasingly complex, GoCompliance provides a centralized, cloud-based platform to manage all aspects of regulatory compliance. Our solution is designed to support your business with scalable tools that streamline documentation, deadline tracking, and submissions.

By choosing GoCompliance, you will receive::

• Pre-configured, out-of-the-box connectivity to Oracle Cloud for accurate product data.
• Advanced BoS and CoC data management for streamlined compliance tracking. 
• Automated status rollups with a configurable engine to ensure accurate reporting. 
• Simplified supplier interactions with a centralized platform for compliance data exchange.
• Fast compliance evidence response, allowing your team to quickly generate and share CoCs, FMDs, and other essential compliance documents.
• Unlimited and custom specifications with fixed pricing and no hidden costs.

Prepare Early to Protect Market Access

The launch of Ukraine’s pre-registration phase is a critical moment for chemical suppliers and manufacturers. Companies that act early will benefit from extended compliance timelines and ensure continuity in their ability to access the Ukrainian market.

GoCompliance is here to support your organization at every step of the process—from preparation to submission and beyond. Our regulatory experts and integrated platform make it possible to manage international compliance requirements with confidence and precision.

Start Your GoCompliance Journey Today

For guidance on navigating Ukraine REACH or to discuss your organization’s compliance strategy contact us or book a demo.