Deadline for Notification to Russian Inventory is extended to 1st Aug. 2020, this will later form part of EURASIA Inventory

Frequently Asked Questions

Russia follows the procedure of establishment of the technical regulation of the Eurasian Economic Union (EAEU) 041/2017 on Chemical product safety.

The Eurasian Economic Union commission is responsible of the TR 041/2017 on the Union level. On the national level each country has its own responsible institutions. 

The responsible institution for the development of the TR 041/2017:

- the Russian ministry of Industry and Trade 

Co-responsible institutions for the TR development:

- Armenian Republic: the ministry of economy

- Belarusian State Concern for Oil and Chemistry

- Kazahstan ministry of development and investment

- Kyrgizian State commitee of industry, energy and soil use

 

At the moment, three countries appointed institutions responsible for the national inventory formation:

Russia: the Ministry of Industry and Trade (MINPROMTORG).

Belarus: the state Commitee of Standarisation (GOSSTANDART)

Kazakhstan: the Ministry of Industry and Infrastructural development

 

Manufactures, importers, nominated representative acting on behalf of forign manufacturer, chemical consumers, authorised bodies of the member states responsible for chemicals and the EAEU commission that is issuing the regulation.

In the Russian Federation, the inventory formation is a part of a timed action plan* aimed at preparing the industry for the entry into force of technical regulation of the Eurasian Economic Union “On the Safety of Chemical Products” (TR  041/2017).

A national inventory is the first stage in the formation of a common "register of chemical substances and mixtures" of the Eurasian Union.

* Action plan picture:

 

 

All chemical substances as such or within the mixture that your company is releasing or just planning to release for Russian (or Union) market are subject of inventory.

For chemical product released for Union’s market as a chemical substance, you need to do an inventory of the main component and all its impurities and supplements presented in a concentration of more than 0.1% (by weight).

For mixtures, it is necessary to take into account all components presented in their composition in a concentration of more than 0.1% (by weight). In a case, if some substance is present in a concentration of less than 0.1%, but there is a probability of its increasing content, we recommend putting such substance into inventory, too.

The substances can be excluded from the inventory submission process if they are a part of chemical products that are specified in Annex 1 of TR 041/2017 (a list of chemical products on which the technical regulation does not apply). For the full list please see the "Excemptions from the Russian inventory" under "Reglutaion" - "The Invenory". 

 

Chemical substances inventory is a voluntary procedure in which a company has the right to submit data on chemical substances for inclusion in the inventory list, thereby declaring them as existing in the customs territory of the Union. The inventory list will be the basis for the formation of the Register of chemical substances and mixtures of the Eurasian Economic Union.

At the inventory stage, the regulator requests minimum information on chemical substances. The submission of information is free of charge and does not require the attaching of any documents.

After the entry into force of the TR 041/2017, all chemical substances that are not in the Register will be considered “new” for the customs territory of the Union.

Before a release of any chemical product containing such new substance, you must undergo a notification procedure of new substances. Notification is a comprehensive study of hazardous properties and analysis of risks to human health and the environment with filling in a chemical safety report. It is expected that only really new and unexplored chemicals will undergo notification procedure.

Those companies that for some reason has not been participated in the inventory and have realized that their substances are not in the Register after the entry force of the TR EAEU 041/2017, (and therefore they identified as new chemicals), can submit data in the Register within a deferred norm: before June 2, 2023 companies have the right to submit information on a chemical substance for inclusion in the Register without a notification procedure, but with attaching of the documents that confirm the circulation of a chemical substance on the Union market before the effective date TR EAEU 041/2017. Confirming documents may include a supply agreement (an act of purchase and sale), consignment note, information on the presence of a chemical substance in the national list of chemicals of a Member state, etc.

After the entry into force of the TR  041/2017 and the termination of the deferred norm, you must notify all chemical substances that are not in the Register before them being released to the Union market (even as part of the mixture).

In Russia, nomination to the inventory can only be done by the resident of Russia (Russian legal entity). A foreign company that does not have a branch in the Russian Federation can appoint a Russian representative for data submission. 

GPC can provide you the Authorised Representative service in Russia to nominate your substances to the inventory.

The information required for each substance nomination includes substance identification (CAS), EU number, RTECS number, IUPAC names in Russian and English, molecular & structural formulas intended use, estimated volume (the average volume of import per year or planned amount),  

You need to complete all sections on an “if applicable” / “if available” basis. However, we recommend providing the information as fully as possible. 

For a substance with complex and variable composition (UVCB substances) such as gasoline, nomination should be submitted for the substance as a whole (without separation into components). CAS number assigned to it should be provided (if any).
For polymer, it is necessary to provide information on monomers, as well as all additives in accordance with the recipe (for example, plasticizers, polymerization activators, etc.) in an amount of more than 0.1% (by weight). With regard to polymers themselves, due to their variability and variety, nomination is not applicable. However, it is optional to nominate polymers to the inventory.

For mixtures it is necessary to take into account all components presented in their composition in a concentration of more than 0.1% (by weight). We recommend including substances that are presented in a concentration of less than 0.1%, in case there is an expansion of the content in the inventory.  


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