Are You Ready for the 2027 Ukraine REACH Pre Registration Deadline?

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08 Oct 2026

Is your company selling finished products into Ukraine? Have you heard that Ukraine has implemented its own Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation, but remain unsure as to what compliance obligations apply to your business? You're not alone.

Many suppliers are still trying to understand how Ukraine’s REACH regulation applies to their products, who is responsible for compliance, and what actions need to be taken before the upcoming deadlines.

The good news? Intertek's REACH specialists are here to help.

What is Ukraine REACH?

The Technical Regulation on the Safety of Chemical Products, commonly known as Ukraine REACH (UA‑REACH ), was introduced by the Ukrainian government to regulate chemical standards. The government approved the regulation on 23 July 2024 and it entered into force on 26 January 2025.

UA‑REACH is largely aligned with European Union (EU) REACH principles. It requires the pre‑registration and registration of substances manufactured in or imported into Ukraine in quantities of 1 tonne or more per year, and applies to substances on their own, in mixtures, and in articles with an intended release.

Also like EU REACH, UA‑REACH follows the principle of "no registration, no market": after the applicable registration deadline, substances requiring registration cannot be manufactured or placed on the Ukrainian market unless the necessary compliance obligations have been fulfilled. This principle makes it essential for companies operating in Ukraine to understand which compliance obligations and registration deadlines apply to their products.

Key Compliance Deadlines

UA‑REACH requires Ukrainian manufacturers and importers to pre‑register their substances with Ukraine’s Ministry of Environmental Protection and Natural Resources. The Ukrainian government extended the original pre‑registration deadline, giving companies until 26 January 2027 to pre‑register.

While this extension provides additional time, companies should not delay preparations; developing a compliance strategy can take significant time and pre-registration is only the first step in the compliance process. Following pre‑registration, full registration deadlines begin in 2028 and continue through 2033. The applicable deadline will depend on the substance’s hazard classifications and tonnage bands.

What Does This Mean for Non‑Ukrainian Manufacturers?

Non‑Ukrainian manufacturers are not required to pre‑register substances, as this responsibility lies with the Ukrainian customers (i.e. importers) that are bringing those finished products into Ukraine. However, many foreign manufacturers choose not to rely solely on their importers to manage compliance activities. Instead, they appoint a person or legal entity within Ukraine, known as a Ukrainian Only Representative (OR), to handle compliance obligations on behalf of their Ukrainian importers.

This approach has several benefits, including:

  • Simplified compliance for Ukrainian customers;
  • Uninterrupted access to the Ukrainian market;
  • Greater visibility and control over compliance strategy;
  • Protection for confidential product formulations and compositional information; and
  • A competitive advantage over suppliers that have not yet addressed UA‑REACH requirements.

For many companies, appointing an OR is the most efficient way to ensure compliance while supporting their customers.

How Intertek Can Help

Intertek's regulatory experts can support your company throughout the entire UA‑REACH compliance process, including:

  • Compliance strategy development: reviewing your product formulations, supply chain, and annual import volumes to determine the applicable deadline and develop a compliance strategy tailored to your business;
  • Ukrainian OR services: acting as your Ukrainian OR and managing compliance activities on behalf of your Ukrainian importers;
  • Pre‑registration support: preparing and submitting required pre‑registrations in advance of the 26 January 2027 deadline;
  • Registration planning: helping you understand future registration obligations and preparing for upcoming deadlines based on tonnage bands and hazard classifications;
  • Ongoing regulatory support: providing continued UA‑REACH compliance support as the regulation evolves and additional requirements come into force; and
  • Global regulatory expertise: helping manage compliance risks and maintain access to markets around the world.

Don't Wait Until the Last Minute

Although the UA‑REACH pre‑registration deadline has been extended, companies should begin evaluating their obligations now. Early preparation allows businesses to identify compliance requirements, assess supply chain impacts, protect confidential business information, and avoid last‑minute challenges.

If your company is supplying products to Ukraine and wants to ensure continued market access for your customers, now is the time to act.

Contact Intertek's REACH team today to discuss your UA‑REACH obligations before the 26 January 2027 pre‑registration deadline.  

A professional headshot of Claire Groves
Claire Dhaliwal

Scientific & Regulatory Affairs Consultant 1, Intertek Assuris

As part of the Global REACH Team, Claire's primary focus and role is assisting her North American clients in maintaining compliance with the REACH regulatory requirements in the EU, UK, Turkey, Ukraine, and India. Claire is involved in managing numerous clients' REACH programs, which includes disseminating and analyzing annual Only Representative (OR) reporting, creation of inquiry and joint registration dossiers using the IUCLID software, and other regulatory support to comply with REACH regulations across the globe. Claire attended McMaster University, where she received an H.B.Sc. in Biology.

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