Ukraine officially launched its REACH regulation, known as UA REACH (Resolution No. 847/2024), on January 26, 2025. Modeled on the EU REACH framework, this legislation establishes a structured system for the registration, evaluation, and management of chemicals on the Ukrainian market. For packaging companies importing raw materials, additives, or polymers, the regulation introduces new compliance obligations that mirror but also differ from EU practices.
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Scope and Applicability
UA REACH applies to all substances manufactured or imported into Ukraine at quantities of 1 tonne or more per year. Both local manufacturers and importers are responsible for compliance. Non-Ukrainian companies supplying chemicals into Ukraine can appoint an Only Representative (OR) based in the country to handle registrations on their behalf.
Unlike EU REACH, Ukraine’s system does not distinguish between “existing” and “new” substances during pre-registration, meaning that all substances above 1 tonne/year require pre-registration.
Pre-Registration Phase (2025–2026)
The first compliance step is pre-registration, which runs from January 26, 2025 to January 26, 2026. During this period, companies must submit:
- Company identification (manufacturer, importer, or OR).
- Substance identification (name, CAS number, molecular and structural formula).
Pre-registration is mandatory for all substances above the 1 tonne threshold, as mentioned earlier, and must be submitted via Ukraine’s national online portal.
Full Registration Deadlines
UA REACH introduces a phased registration system based on tonnage and hazard classification. Key deadlines include:
- By January 26, 2026:
- All new substances.
- Carcinogenic, Mutagenic, or Reprotoxic (CMR, Category 1A and 1B) substances ≥1 t/year.
- Substances hazardous to the aquatic environment (Category 1) ≥100 t/year.
- By October 1, 2026: Substances produced or imported at ≥1,000 t/year.
- By June 1, 2028: Substances produced or imported at 100–1,000 t/year.
- By March 1, 2030: Substances produced or imported at 1–100 t/year.
Key Provisions
UA REACH aligns with the European Union’s chemical safety framework but has notable features:
- One system for all substances: No transitional differentiation between new and existing chemicals.
- Broad applicant base: Manufacturers, importers, and ORs can register.
- Hazard prioritization: CMR and highly hazardous substances face the earliest deadlines.
- Integration with CLP: A companion regulation, UA CLP, aligns classification, labeling, and safety data sheet requirements with GHS and EU CLP standards.
Implications for the Packaging Sector
For packaging producers and suppliers, UA REACH compliance is critical when sourcing raw materials such as plastics, adhesives, coatings, and inks. Companies that import into Ukraine must ensure:
- Early pre-registration of all relevant substances to maintain market access.
- Coordination with suppliers and ORs to avoid duplication or registration gaps.
- Long-term planning for data requirements, especially for higher-volume or hazardous substances.
Failure to meet registration deadlines could restrict market entry and disrupt supply chains.
Conclusion
UA REACH is an important step for Ukraine’s alignment with EU chemical safety rules and harmonization with trade standards. For the packaging industry, the regulation presents both challenges and opportunities, with compliance requiring careful planning and investment, but also creating a predictable framework that supports safer, more sustainable material use. Companies engaging with the Ukrainian market should act now to prepare for upcoming deadlines, ensuring their materials remain compliant and competitive in this evolving regulatory environment.
