Are You Ready for the Latest Approved GHS Regulation (UA CLP) in Ukraine?

On December 1, 2022, Ukraine adopted the law “on ensuring chemical safety and management of chemical products” which was set to take effect on June 29, 2024. Article 35 and 36 stipulate that the classification and labelling of chemical substances shall conform to the GHS system. This legislation is part of Ukraine’s commitments to integrate with the European standards, aiming to safeguard both the public health and the environment.

Then on May 10, 2024, the Ukrainian government (Міністерство захисту довкілля та природних ресурсів України) adopted the “Technical Regulation for the Classification of Hazards, Labelling and Packaging of Chemical Products” (also known as UA-CLP). This aligns Ukraine with the EU (EU Regulation 1272/2008) and UN GHS. The original name of this regulation is Про затвердження Технічного регламенту класифікації небезпечності, маркування та пакування хімічної продукції (Approval of the Technical Regulation for the classification of hazards, labelling and packaging of chemical products).

The UA CLP came into effect six months after its publication, on November 15, 2024. Products that have been placed on the market before November 15, 2024, even if they do not comply with current technical regulations, can continue to maintain their status until November 14, 2025, which is a one-year transition period.

The following two parts will come into effect on January 1, 2025:

• Part 3: Labeling chemical products with information about hazards; and
• Part 6: Clauses 130-133: Authorized bodies in the field of ensuring chemical safety and management of chemical products.

The classifications of UA CLP are basically consistent with that of EU CLP, covering 33 hazard classes related to physical, health, and environment risks. The requirements for chemical labeling and packaging are almost the same as those of the EU CLP.

In addition, the Ukrainian REACH regulation (Technical Regulation for the Safety of Chemical Products) (UA REACH) was officially announced in July 2023, which also incorporates GHS-related requirements, including the explicit requirement to provide Safety Data Sheets (SDS) for chemicals.

Related Links

Ukrainian REACH will Take Effect on January 23, 2025

The scope of application of UA CLP does not cover chemical products in a “finished state, intended for use by the final consumer” including medical devices, veterinary medicinal products, food or feed products, tobacco products, and cosmetic products.

However, although cosmetic products are exempted from the UA CLP, the ingredients of cosmetic products are still subject to the management of this regulation. This is particularly important for ingredients containing CMR (class 1A or 1B of carcinogenic, mutagenic, or toxic for reproduction) substances or mixtures. The use of similar raw materials could be avoided after judging the substances’ classification based on the latest UA CLP.

CIRS will host a free webinar on the Ukrainian chemical regulations on December 18, 2024. Please click here to find out more and register.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.