Ukraine is systematically moving toward harmonizing its national legislation with European Union law, with the implementation of chemical safety regulations being one of the most significant transformations. This primarily involves the implementation of Regulation (EC) No 1907/2006 (REACH) regarding the registration, evaluation, authorization, and restriction of chemicals, as well as Regulation (EC) No 1272/2008 (CLP) regarding the classification, labeling, and packaging of substances and mixtures. These two documents form the foundation of the EU’s chemical product management model, defining operational rules for manufacturers, importers, distributors, and logistics operators.
The Fuel and Energy Business Association (FEBA) supports Ukraine’s strategic path toward European integration. For the fuel sector, product safety, public health protection, and environmental responsibility are integral to market development. However, the practical implementation of REACH and CLP in Ukraine requires not a mechanical copy of European models, but the creation of an adapted mechanism that considers the structure of the Ukrainian economy, the consequences of martial law, and the actual state of fuel infrastructure.
This issue extends far beyond technical regulation. The fuel and energy sector ensures the functioning of critical national infrastructure, logistics stability, the agricultural sector, industry, healthcare, and defense systems. Therefore, any changes in the regulation of petroleum products must be evaluated not only through the prism of formal compliance with EU law but also through their impact on fuel supply continuity and market stability.
FEBA, which unites key market players—from network and independent gas stations to importers and logistics companies—views the implementation of REACH and CLP through the lens of the entire supply chain, from import and storage to transportation and final retail.
Implementation Risks and Challenges
Experts from FEBA member companies have analyzed the Technical Regulation on the classification and labeling of chemical products (Cabinet of Ministers Resolution No. 539, May 10, 2024), based on REACH and CLP. It is already evident that the proposed implementation model creates significant risks, particularly given the timeline. Despite the Government’s decision to postpone certain deadlines (Resolution No. 1598, December 5, 2025), a large part of the market is objectively not ready to meet all requirements on time.
The problem is not just labeling or Safety Data Sheets (SDS). REACH establishes the “no data, no market” principle (Articles 5 and 6), prohibiting the circulation of substances without prior registration. This obligation starts at volumes of just one tonne per year. At higher tonnages (10+ tonnes), a Chemical Safety Assessment becomes mandatory, and at 100+ tonnes, a full Chemical Safety Report is required.
The Complexity of Petroleum Products
The situation is complicated by the fact that primary petroleum products—gasoline, diesel, LPG, and base oils—fall into the UVCB category (substances of Unknown or Variable composition, Complex reaction products, or Biological materials). Registering these is technically complex and costly. In the EU, this was supported by decades of data-sharing consortia and “read-across” procedures. Ukrainian businesses currently lack access to this infrastructure, placing the entire burden of proof for product safety on individual market operators.
Financial and Operational Burden
The preparation of a single REACH dossier can cost between €20,000 and €150,000, depending on substance complexity. Companies also pay administrative fees to the European Chemicals Agency (ECHA) and must acquire a ‘letter of access’ for existing data, which can cost €5,000 to €50,000 per substance. For the fuel sector, which deals with dozens of components and additives, this creates a multiplier effect on financial obligations.
Recommendations for a Phased Implementation
The EU implemented REACH in stages over more than a decade with significant institutional support. Ukraine is currently approaching a model of near-simultaneous application without similar infrastructure or consideration of martial law constraints. FEBA advocates for:
- A phased implementation model: A transition period of 5–7 years with differentiated requirements based on tonnage, business scale, and supply chain role.
- Regulatory streamlining: Settlement of issues regarding UVCB substances, the adoption of “read-across” procedures, and the automatic recognition of specific EU registration data.
- Infrastructure for data-sharing: Mechanisms to prevent the duplication of costs.
- Support for SMEs: A special adaptation regime for small and medium-sized enterprises, including simplified procedures, deferred requirements, and a moratorium on penalties during the initial system launch.
European integration is not just the formal transposition of norms; it is about creating a system that functions, ensures safety, and maintains the economic resilience of the state. It is vital that the business sector, which ensures the daily operation of the country’s critical infrastructure, remains a full participant in shaping the REACH and CLP implementation model in Ukraine.
