1. Why CLP Matters for Ukrainian Businesses

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Ukraine is transitioning to European standards for chemical product management in accordance with the Law “On Ensuring Chemical Safety and Chemical Product Management.”
CLP (Classification, Labelling and Packaging) is a technical regulation establishing a unified system for classifying hazards and labeling chemical substances, aligned with the global UN GHS system.

What this means for business:
– new requirements for labeling and packaging;
– correct use of hazard pictograms;
– responsibility for the accuracy of information on labels;
– increased attention from market surveillance inspections.

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2. The Chemical Safety Law — the Foundation of Change

The new Law introduces clear definitions such as: “chemical substance,” “hazardous substance,” “highly hazardous substance,” “risk assessment,” “safety assessment,” etc.
These terms are essential for the proper application of CLP and REACH requirements.

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3. CLP: What the Technical Regulation Covers

The Technical Regulation on classification, labeling and packaging (TR CMP) is harmonized with Regulation (EC) No 1272/2008 (CLP).

Key requirements:

• how to determine the hazardous properties of substances and mixtures;

• which pictograms and signal words to apply;

• how to correctly use hazard (H) statements and precautionary (P) statements;

• how a GHS-compliant label must look;

• the 10th edition of GHS has been in force since 2023.

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4. REACH: Registration and Control of Chemical Substances

The second major document is the Technical Regulation based on REACH (Regulation (EC) No 1907/2006).

It regulates:

• registration of chemical substances;

• risk assessment;

• authorisation for the use of Substances of Very High Concern (SVHC);

• restrictions for certain components.

For manufacturers of furniture and coatings (paints, lacquers, adhesives), this means the need to analyse the components of glues, varnishes, paints for potential restrictions and REACH requirements.

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5. The Role of the State Environmental Inspectorate

The State Environmental Inspectorate is the designated market surveillance authority for chemical products.

Its legal powers include:

• control of labeling and safety;

• requesting documentation (Safety Data Sheets, instructions);

• checking the implementation of risk-mitigation measures;

• applying sanctions.

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6. Large-Scale Training for Inspectors in November 2025

A training course for 49 employees of the State Environmental Inspectorate was held on 19–21 November 2025 with OSCE support.

Course specifics:

• preparation for applying the CLP Technical Regulation;

• study of practical labeling cases;

• final testing by December 1.
  Participants who score at least 70 points receive a state-issued certificate.

On November 20, an open online seminar was held with 388 participants from business, education and NGOs (including UAFM members).

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7. CLP Methodological Guide: Uniqueness and Value

https://livingplanet.org.ua/images/2025/metodychnyy_posibnyk_clp.pdf

The guide, prepared in a Q&A format, includes:

• explanations of the CLP Regulation requirements;

• examples of correct and incorrect labeling;

• clarification on hazard classification;

• recommendations for businesses on preparing for inspections.

Useful for:

• manufacturers;

• importers;

• distributors;

• regulatory authorities;

• all professionals working with chemical products.

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8. Market Surveillance Reform — What Changes for Businesses

According to the Ministry of Economy:

• the focus shifts from punishment to prevention;

• supervisory functions will be integrated into a single authority;

• processes will be digitalised;

• laboratory capacity will be strengthened;

• 24/7 rapid response will be implemented.

For businesses this means:

• more predictable procedures;

• fewer chaotic inspections;

• clear requirements for documentation and labeling.

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9. Action Plan for Businesses

1. Conduct classification of chemical product hazards

Companies manufacturing, importing or supplying chemical products or goods containing chemicals must:

• identify hazardous properties according to GHS criteria;

• prepare required labeling elements (pictograms, signal words, H- and P-statements);

• submit classification and hazard information to the Ministry.

2. Conduct an inventory of chemical substances in products

It is necessary to:

• compile a full list of substances included in products and used in processes;

• obtain or update Safety Data Sheets (SDS) for each substance or mixture;

• determine which substances require state registration.

3. Submit preliminary state registration of chemical substances

All substances subject to registration must be submitted to the Ministry and undergo preliminary registration — mandatory for:

• manufacturers,

• importers,

• suppliers and distributors,

• other market operators.

4. Update labeling and packaging

Businesses must update:

• labels according to hazard classification;

• warning elements;

• user information;

• safe packaging requirements.

5. Update or create Safety Data Sheets (SDS)

The SDS must be prepared or revised according to new requirements:

• structure and content must comply with the Technical Regulation;

• information must match the actual classification and labeling.

6. Establish an internal chemical safety system

Companies must:

• appoint responsible persons;

• introduce internal audits of chemical products;

• maintain and regularly update documentation;

• prepare for possible inspections.

Businesses can perform all procedures independently or seek support from consultants.

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 +38 099 642 81 57 (WhatsApp, Telegram, Viber)
info@livingplanet.org.ua

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Useful links:

Additional explanations

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Training course