On 22 October 2025, a draft 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.
In the draft that is published by Ministry of Economy, Environment and Agriculture (MEEA) the amendments primarily extend timelines to align with the phased for giving industry additional time for dossier preparation and labelling updates. Please note that these amendments are still draft and not in force.
The main amendments introduced by this draft regulation are as follows:
- The institutional authority has been transferred from the Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR) to the Ministry of Economy, Environment and Agriculture of Ukraine (MEEA). Accordingly, all processes related to registration, evaluation, restriction, and other UA REACH/CLP -related activities for the Ukrainian market will now fall under the competence of this Ministry.
- To allow companies more time to comply with the legal requirements, the relevant deadlines have been updated as follows:
| Process | Previous Deadline | Updated Deadline |
| UA REACH Pre-registration Deadline | 26 January 2027 | |
| UA REACH Registration Deadlines | ||
| Substances classified as CMR (Cat. 1A and Cat. 1B) in quantities of ≥ 1 ton/year Substances classified as H400 and H410 (Cat. 1) in quantities of ≥ 100 ton/year | 1 October 2028 | |
| Substances manufactured or imported ≥ 1000 tonnes/year | 1 October 2029 | |
| Substances manufactured or imported between 100–1000 tonnes/year | 1 June 2031 | |
| Substances manufactured or imported between 1–100 tonnes/year | 1 March 2033 |
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.
The draft has been published on the official website of the Ministry of Economy, Environment and Agriculture of Ukraine for public consultation, and the approval process of the decree has not yet been finalized. Click here to access the official announcement and share your comments on the draft.
Don’t forget to subscribe to our newsletter for future updates on the subject.
You can review the related documents through 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”
