Have UA REACH Dates Been Postponed?

The draft regulation titled “On Amendments to the Resolutions of the Cabinet of Ministers of Ukraine of May 10, 2024, No. 539 and of July 23, 2024, No. 847” was published on October 22, 2025, introducing several important changes. These are summarized below:

UA CLP

Transition Period
The compliance period for chemical products already placed on the market to meet the requirements of the Technical Regulation has been extended from 1 year to 18 months.

Labelling and Packaging
Products placed on the market before January 1, 2027, may remain available until July 1, 2028, even if their labelling or packaging does not yet comply with Sections 3 or 4 of the Regulation.

Classification

The deadline for placing chemical substances not classified for hazards according to the CLP criteria specified in Annex I of the UA CLP on the market has been changed to November 15, 2027.
The deadline for placing mixtures not classified for hazards according to the CLP criteria specified in Annex I of the UA CLP on the market has been changed to May 1, 2028.

UA REACH

Registration Timeline

Tonnage Band	Previous Deadline	New Deadline
≥1 tonne/year; substances classified as CMR (Category 1A and 1B) ≥100 tonnes/year; substances classified as H400 and H410 (Category 1)	January 26, 2026	October 1, 2028
≥1000 tonnes/year	October 1, 2026	October 1, 2029
100–1000 tonnes/year	June 1, 2028	June 1, 2031
1–100 tonnes/year	March 1, 2030	March 1, 2033

Administrative Changes

The competent authority has been changed from the Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR) to the Ministry of Economy, Environment and Agriculture (MEEA).

Pre-registration Timeline

Previous Deadline	New Deadline
January 26, 2026	January 26, 2027

Important Note:

Please note that in this draft, A six-month extension could be assumed for C&L Notification, potentially indicating a new deadline around 15 May 2026. Since the currently in-force deadline remains 15 November 2025, preparing a C&L Notification in advance would be an important step to ensure regulatory compliance and market safety.

You can access the official announcement published by the Ministry here, and review the related documents via the links below:

EXPLANATORY NOTE to the Draft Resolution of the Cabinet of Ministers of Ukraine “On Amendments to the Resolutions of the Cabinet of Ministers of Ukraine of May 10, 2024, No. 539 and of July 23, 2024, No. 847”
AMENDMENTS to the Resolutions of the Cabinet of Ministers of Ukraine dated May 10, 2024, No. 539 and July 23, 2024, No. 847
COMPARISON TABLE to the Draft Resolution of the Cabinet of Ministers of Ukraine “On Amendments to the Resolutions of the Cabinet of Ministers of Ukraine of May 10, 2024, No. 539 and of July 23, 2024, No. 847”