Under Ukraine’s REACH legislation, non-Ukrainian manufacturers intending to export chemical substances, mixtures, or certain articles to the Ukrainian market are required to appoint an Only Representative (OR) to fulfil their regulatory obligations.
If you’re a non-Ukrainian manufacturer looking to place your chemical products on the Ukrainian market, you need to comply with UA REACH Regulation. Appointing an Only Representative (OR) allows you to meet registration requirements without relying on your importers. Chemleg can support your company with this process.
What Does a Ukraine REACH Only Representative Do?
- Registration and Pre-registration: Manages the registration and pre-registration of substances in quantities of 1 tonne or more per year placed on the Ukrainian market.
- Data Sharing: Joins Substance Information Exchange Forums (SIEFs) formed for sharing information with other companies exporting the same substance and handles communication on behalf of the manufacturer.
- Communication with Authorities: Acts as the official liaison with competent authorities such as the Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR).
- Safety Data Sheets (SDS): Prepares Safety Data Sheets in Ukrainian for hazardous substances and mixtures and ensures they are provided throughout the supply chain.
- Assumption of Obligations: Once an Only Representative is appointed, importers are exempt from registration obligations and instead acquire “downstream user” status.
Why is Ukraine REACH Only Representation Beneficial?
Through the Ukraine REACH Only Representation service, the party responsible for the safety of each chemical substance sold in Ukraine is clearly identified. The Only Representative assumes full legal responsibility on behalf of the manufacturer, relieving importers of their obligations. Without an appointed OR, each Ukrainian importer must independently register the substance they import. For this reason, a non-Ukrainian manufacturer may prefer to appoint an Only Representative to protect the confidentiality of their chemical substances.
Having an OR ensures that competent authorities can communicate with a single, legally recognized entity within Ukraine, simplifying inspections and enforcement. Moreover, implementing an OR system aligns Ukraine’s approach with the EU REACH Regulation and facilitates compliance with international trade standards and relations with the EU. For all these reasons, Ukraine’s legislation allows the appointment of an Only Representative.
Who Can Be Appointed as a Ukraine REACH Only Representative?
Legal entities established in Ukraine with technical expertise and knowledge of chemical regulations can be appointed as Only Representatives. Chemleg offers professional OR services in this area.
As your Ukraine REACH Only Representative, Chemleg provides:
- Legally Compliant Representation – Acting as your official representative under UA REACH.
- Substance Registration & Notification – Handling dossier preparation and submission.
- Safety Data Sheets (SDS) & Compliance – Ensuring compliance with Ukrainian regulations.
- Communication with Authorities – Managing interactions with regulatory bodies.
- Supply Chain Support – Assisting your customers with compliance requirements.
By appointing us as your OR, you maintain market access while ensuring confidentiality and regulatory compliance. Fill out the form to schedule a consultation with our experts.
Frequently Asked Questions
What happens if I don’t appoint an Only Representative for Ukraine REACH?
If no OR is appointed, Ukrainian importers become the legally responsible party and must complete all REACH registration processes themselves. This imposes additional costs and administrative burdens on the importer. Offering OR services can make your products more attractive to Ukrainian buyers.
Which substances require the appointment of a Ukraine REACH Only Representative?
All chemical substances exported to Ukraine in quantities of 1 tonne or more per year are subject to the OR requirement. For exceptions, the regulation should be reviewed.
Can a Ukraine REACH Only Representative be changed?
Yes, but this requires terminating the relationship with the previous OR and updating the authorization documents. Chemleg can also assist you during transition periods.
