The Ministry of Environmental Protection and Natural Resources of Ukraine (MEPR) has officially released the pre-registration template for chemical substances under the Ukraine REACH Technical Regulation. This is a significant step in the implementation of the national REACH framework, enabling businesses to start pre-registering substances placed on the Ukrainian market.

Who Must Pre-Register?

As outlined in the transitional provisions of Ukraine REACH, the following actors must pre-register substances manufactured or imported at ≥1 tonne per year, unless they are specifically exempted:

• Manufacturers

• Importers

• Only Representatives (ORs) acting on behalf of non-Ukrainian entities.

Pre-registration is mandatory in order to benefit from the staggered registration deadlines and ensure continued access to the Ukrainian market.

Pre-Registration Timeline

• Start Date: 26 January 2025

• Deadline: 26 January 2026

Registration Deadlines

• 26 January 2026: CMR substances (Category 1A and 1B) above 1 tonne per year, and substances very toxic to aquatic organisms (acute or chronic) above100 tonnes per year.

• 1 October 2026: Substances above 1,000 tonnes per year.

• 1 June 2028: Substances from 100 to 1,000 tonnes per year.

• 1 March 2030: Substances from 1 to 100 tonnes per year.

Pre-Registration Template and Submission Instructions

To streamline the compliance process, the MEPR has introduced a standardized Excel-based pre-registration form, which is only available in Ukrainian.

The form must be:

• Completed per substance

• Filled out in Ukrainian

• Electronically signed using a Qualified Electronic Signature (QES)

• Submitted along with supporting documents, and (if applicable) an Only Representative appointment letter

Completed forms should be submitted to [email protected]

The official template and instructions can be found on the MEPR website.