Ukraine Adopts Revised RoHS Exemptions And Supplier-Information Duties

Ukraine adopted Resolution No.1153 on 17 September 2026, amending its restriction-of-hazardous-substances rules for electrical and electronic equipment. It entered into force on 19 September.

The amendments update Annex 3 exemptions under Resolution No.139/2017, including mercury in discharge lamps and lead in specified alloys, solders and electrical applications. They do not impose a blanket prohibition on all lead or mercury in equipment.

Exemption Conditions And Expiry Dates

Dates vary by entry and equipment category. Entry 6(a) expires on 11 December 2026, entry 6(b) on 11 June 2027, and entry 7(c)-II on 31 December 2027. Entries 6(b)-I and 6(b)-II have category-dependent dates.

A new footnote narrows marked lead exemptions for general-public equipment or accessible parts that children can mouth. The exemption requires lead release not exceeding 0.05 micrograms per square centimetre per hour. Where a coating is used, it must maintain that limit for two years under normal or reasonably foreseeable use.

That condition applies with the amendment's commencement; it is not postponed until each entry's later expiry date.

Identification And Documentation

Amended paragraphs 19 and 27 address manufacturer and importer identification. The explicit single-contact-location requirement appears in the manufacturer provision. Paragraphs 21 and 31 require documentation and information following a reasoned authority request, in a language the authority can understand, together with cooperation on corrective action.

The amendments also change Annex 5 declaration-of-conformity wording. Compliance therefore depends on the Ukrainian text, its application-specific exemptions and dates, rather than assuming an EU RoHS technical file establishes compliance automatically.