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What are the next steps? Three scenarios of compliance strategies in EAEU after 1st of August 2020  

The Russian Ministry of Industry and Trade (Minpromtorg) has published a transitional - inventory of chemicals, which will feed into the Eurasian technical regulation on the safety of chemical products – also known as TR EAEU 041/2017 and Eurasia-REACH. Companies have been given a deadline for notifications to the Russian Inventory until 1st of August.  

GPC summarizes three scenarios of compliance strategies for companies planning or that have already placed chemical substances in the Eurasian Economic Union (EAEU):    

1.     Start to Prepare for Pre-registration if substances have been nominated to the Russian Inventory:   

 If companies have nominated substances to the Russian inventory and this nomination has been approved - meaning that they are now listed in the Russian Inventory, then GPC recommends companies to start preparing for pre-registration. GPC will keep you updated on the pre-registration date and deadlines. Once the authorities announce the date of the pre-registration, GPC can help you.  

2.     If companies have missed the deadline for notifying substances to the inventory  

Chemical substances that are not present in the Russian Inventory will be considered as "new" chemicals for the market. In order to place a "new" chemical substances on the Russian market, companies will need to follow the standardized "permissive" registration procedure for substances that are considered as "new" (including; laboratory experiments and extensive documentation). However, for those companies who have been importing substances to the Russian market before the enforcement of TR 041 (2 June 2021) there is a possibility to notify substances through an “exceptional” procedure. In this case, companies can continue to nominate substances to the Russian Inventory providing basic information and documentation proving that chemicals have been placed on the Russian market before the TR041 enforcement (2 June 2021).   

3.     If companies have missed the deadline for notifying substances to the inventory and have not been importing chemicals to Russia before 2 June 2021.  

 Companies will need to follow the TR 041 notification procedure if their substances are not presented in the Russian Inventory and they were not importing such substances before 2 June 2021. In this case,substances will be considered as “new" substances and nomination to the inventory will require laboratory experiments and extensive documentation.  

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Latest News

Ukrainian updated toy regulation in line with Directive 2009/48/EC of the EU

In September 2020, the Ukrainian government published a draft resolution of changes to the Ukrainian Technical regulation on Toy’s safety.

The changes in the Technical Regulation are prepared to bring the provisions of the Technical Regulation in line with the provisions of Directive 2009/48/EC of the European Parliament and of the Council which also provides the basis for the Ukrainian Technical Regulation on Toy’s Safety. The proposed changes to the regulation suggest for lowering the limits for chromium (VI) and aluminium (table 1) in toys and toy materials, as well as limiting the amount of formaldehyde (table 2).


Table 2

According to the Ukrainian Cabinet of Ministers, the implementation of the law will have a positive impact since it demands more stringent requirements for limitation of chemicals that are hazardous and/or are classified as carcinogenic, mutated or toxic. Consequently, this resolution will ensure a higher quality level of toys and better protection for consumers.

Ukraine’s new Technical Regulation on Toy’s Safety was adopted in February 2018 and replaced the former Technical Regulation adopted in 2013.  However, all toys that complied with the 2013 Technical Regulation were still allowed for circulation on the Ukrainian market even after the new Technical Regulations entrance into force. The institution responsible in ensuring the implementation of the Technical Regulation on Toy’s Safety is the Ministry for Development of Economy, Trade and Agriculture of Ukraine.



Russia has identified responsible institutions for implementing TR 041

The Government of the Russian Federation has identified responsible institutions for implementing the Eurasian Technical Regulation 041(TR 041), an official decree published on 16 September 2020.The Ministry of Industry and Trade of Russia and the Agency of Wellbeing and Consumer rights are two government organizations that will be assigned for executing the TR 041.  

The Ministry of Industry and Trade of Russia (Minpromtorg) will be the main authorized federal executive body. The major tasks of Minpromtog are: the notification of New Chemical Substances (to be a part of the national inventory).  

  • To perform notification of new chemical substances by entering information on new chemical substances into the national part of the inventory.  
  • To perform registration (notification and permissive) of chemical substances based on the documents and information submitted by the applicant, information  by Ministry’s expert organization and the conclusion of Agency of Wellbeing and Consumer rights (hereafter referred to as Rospotrebnadzor) in case if chemical products contain new chemical substances;  
  • Formation and maintenance of the national (Russian) part of the inventory of chemicals and mixtures of the Eurasian Economic Union;  
  • Representation of interests of the Russian Federation in interaction with international organizations concerning the regulation of chemicals and mixtures.  

Rospotrebnadzorhas been appointed as the authorized federal executive body to carry out following tasks:  

  • Notification of new chemicals and providing the corresponding conclusions to the Ministry of Industry and Trade of Russia (Minpromtorg);  
  • Assessment of New Chemical Substances in terms of their danger to human health and the environment and providing a corresponding conclusion to Minpromtorg.  
  • To assist (within its competence) the Minpromtorg in implementation of TR 041.  

According to the decree, a number of federal executive authorities, such as the Ministry of Natural Resources of Russia, the Ministry of Economic Development of Russia, the Ministry of Agriculture of Russia, the Ministry of Energy of Russia, the Ministry of Health of Russia and Rosstandart, might be involved in the process of implementing TR 041 in the near future.  The next step of TR 041 is a ratification of the above services and a finalization of formation of a national part of the inventory in Russia by the end of 2020.