Ukraine Adopts CLP-like and REACH-like Regulations.

UA-CLP: On May 10, 2024, the Ukrainian government adopted the “Technical Regulation for the Classification of Hazards, Labelling and Packaging of Chemical Products” (“UA-CLP), which aligns Ukraine with EU and Global (GHS) Chemical Safety Standards. 

Ukraine will indeed implement the 33 hazard classes applied in the EU  and requirements for labelling and packaging.

 The text of the regulation, including Annex VIII “Correspondence Table between EU CLP and UA-CLP” can be found via the link: Про затвердження Технічного регламенту класифікації небезпечності, маркування та пакування хімічної продукції | Кабінет Міністрів України (kmu.gov.ua)

The following provisions will become effective on January 1, 2025:

• Section 3 ‘Labeling chemical products with information about hazards’
• Section 6 Clauses 130-133 ‘Authorized bodies in the field of ensuring chemical safety and management of chemical products’

Chemical products not complying with the technical regulation, but which were placed onto the market before November 15, 2024, may remain on the market until November 14, 2025.

UA-REACH: On July 23, the Ukrainian government has approved the “Technical regulation for the safety of chemical products” (Ukraine REACH, UA REACH), which aligns with the EU REACH and other global REACH-like regulations, such as Turkish KKDIK, Korean REACH, UK-REACH.

Ukraine will therefore implement, among others:

• Deadlines for registration of chemicals, whether on their own, in mixtures or in articles, if they meet certain criteria and threshold levels (no data, no market) 

(deadlines starting from 1 October 2026 for volumes >1000 ton/year, CMR substances (Category 1A and 1B) at ≥1 t/a and substances very toxic to aquatic organisms (acute or chronic) at ≥100 t/a,  and with last deadline on 1 March 2030 for tonnage band 1-100 ton/year)

• registration requirements
• criteria for notification of substances of very high concern (SVHC) in articles. Notification applies six months after the SVHC has been added to the (Candidate) list
• authorized representatives (only representatives, OR) 
• requirements for a safety data sheet (SDS)
• the authorization list with their latest application and sunset dates (Annex XIV)
• restrictions (Annex XVII), consistent with Annex XVII of EU REACH.

The new law will enter into force on January 26, 2025 – six months after the date of its publication. The full text of the regulation can be accessed here (in Ukrainian).

What This Means for Companies manufacturing or importing chemicals in Ukraine:

All substances and mixtures on the Ukranian market will need to be classified

Substances (on their own or in a mixture) manufactured or imported will need to be registered in Ukraine 

A compliant SDS will be needed for hazardous substances and mixtures, according to UA REACH requirements

It is crucial for companies to plan their actions to ensure they meet new UA REACH and CLP requirements to stay on the market or to explore new ones.