EBA сalls for postponement of new chemical regulation

06/ 10/ 2025

The European Business Association consistently and actively advocates for postponing the enforcement of the Technical Regulation on the Safety of Chemical Products (REACH) and the Technical Regulation on the Classification, Labelling, and Packaging of Chemical Products (CLP). Member companies of the EBA’s Subcommittee on Chemical Safety fully support Ukraine’s commitment to European integration, including in the field of chemical product regulation. However, based on the experience of EU member states and an analysis of the provisions of the REACH and CLP Technical Regulations, business representatives note that the effective and timely implementation of these requirements will demand significant financial, administrative, and human resources, as well as considerable time for full adaptation to the new standards. Companies emphasise that the Resolutions of the Cabinet of Ministers of Ukraine No. 847 dated 23 July 2024 and No. 539 dated 10 May 2024, which approved the REACH and CLP regulations respectively, require corresponding amendments. The business community has already submitted its proposals and recommendations to the Ministry of Economy, the Ministry of Environmental Protection, and the Ministry of Agrarian Policy of Ukraine. Among the amendments proposed by the EBA to the REACH Technical Regulation are: To postpone the deadlines for preliminary state registration of chemical substances for 30 months from the date of the Regulation’s entry into force; To extend the deadlines for state registration of chemical substances in stages, for periods of two years or more; To allow the sale of chemical products that were already in circulation before the Regulation came into effect until the end of their shelf life, provided that such products were supplied in a ready-to-use form intended for final consumers; To introduce certain changes to the sections concerning the state registration of chemical substances already registered in the EU, as well as substances contained in plant protection products and disinfectants (biocides). Among the amendments proposed by the EBA to the CLP Technical Regulation are: To postpone the implementation of Sections 2 and 3 until 2028 for chemical substances and until 2031 for mixtures; To postpone the requirement for creating and including a Unique Formula Identifier in chemical product hazard information until 2031; To defer until 2032–2035 the deadlines for providing information used to develop emergency medical response and preventive measures for chemical exposure. The EBA highly values the Ministry’s openness to dialogue with the business community and looks forward to constructive cooperation.

Member companies of the EBA’s Subcommittee on Chemical Safety fully support Ukraine’s commitment to European integration, including in the field of chemical product regulation. However, based on the experience of EU member states and an analysis of the provisions of the REACH and CLP Technical Regulations, business representatives note that the effective and timely implementation of these requirements will demand significant financial, administrative, and human resources, as well as considerable time for full adaptation to the new standards.

Companies emphasise that the Resolutions of the Cabinet of Ministers of Ukraine No. 847 dated 23 July 2024 and No. 539 dated 10 May 2024, which approved the REACH and CLP regulations respectively, require corresponding amendments. The business community has already submitted its proposals and recommendations to the Ministry of Economy, the Ministry of Environmental Protection, and the Ministry of Agrarian Policy of Ukraine.

Among the amendments proposed by the EBA to the REACH Technical Regulation are:

To postpone the deadlines for preliminary state registration of chemical substances for 30 months from the date of the Regulation’s entry into force;
To extend the deadlines for state registration of chemical substances in stages, for periods of two years or more;
To allow the sale of chemical products that were already in circulation before the Regulation came into effect until the end of their shelf life, provided that such products were supplied in a ready-to-use form intended for final consumers;
To introduce certain changes to the sections concerning the state registration of chemical substances already registered in the EU, as well as substances contained in plant protection products and disinfectants (biocides).

Among the amendments proposed by the EBA to the CLP Technical Regulation are:

To postpone the implementation of Sections 2 and 3 until 2028 for chemical substances and until 2031 for mixtures;
To postpone the requirement for creating and including a Unique Formula Identifier in chemical product hazard information until 2031;
To defer until 2032–2035 the deadlines for providing information used to develop emergency medical response and preventive measures for chemical exposure.

The EBA highly values the Ministry’s openness to dialogue with the business community and looks forward to constructive cooperation.