Ukraine Adopts Revised RoHS Exemptions And Supplier-Information Duties

The measure updates Annex 3 of the regulation adopted by Resolution No. 139/2017. It restructures exemptions for mercury in discharge lamps and lead in steels, aluminium and copper alloys, solders and specified electrical applications.

Several entries now carry expiry dates including 11 December 2026, 30 June 2027 and 31 December 2027. Other exemptions remain available until a date is set by the Cabinet. Businesses must therefore review each material, component and equipment category against its exact exemption rather than treat the amendment as a single lead or mercury phase-out.

Ukraine RoHS Duties Also Affect Identification And Evidence

The resolution clarifies that manufacturers and importers must provide their full name, registered trade name or trademark and a single contact postal address on the equipment, packaging or accompanying documents, as applicable. They must supply technical documentation and information to market-surveillance authorities in a language the authority can understand and cooperate on corrective action.

The amended annex includes new or revised exemptions for lead in specified hot-dip galvanised steel components, certain aluminium casting alloys and particular high-temperature solders. A separate note narrows reliance on some lead exemptions for products or accessible parts that children can place in their mouths, unless very low lead release throughout the product's life can be demonstrated.

The amended regulatory text and associated evidence duties apply now. The loss or narrowing of exemptions applies later on each entry's expiry date. Unchanged provisions include the broader substance restrictions, conformity-assessment structure and market-surveillance framework under Resolution No. 139/2017.

Manufacturers should connect bills of materials, supplier declarations, technical files and declarations of conformity to the precise Ukrainian exemption number and expiry date. Importers should confirm that economic-operator details and local-language documentation are available before placing equipment on the market. Distributors should escalate products whose exemption evidence is missing or due to expire.

Foresight analysis: the earliest December 2026 dates make this an immediate evidence-management issue even where redesign is not yet required. Businesses using European Union RoHS files as a starting point should not assume that exemption numbering, wording or expiry timing is identical in Ukraine.

Practical call to action: Create an exemption register by component, Ukrainian entry and expiry date, beginning with all entries ending on 11 December 2026.