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):
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.
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 the TR041 enforcement (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.
The Government of the Russian Federation has identified responsible institutions for implementing the Eurasian Technical Regulation 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).
Rospotrebnadzor has been appointed as the authorized federal executive body to carry out following tasks:
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.
The nomination period for the Russian Inventory is formally closed now. During this nomination period, the GPC group has helped 20+ companies to nominate 350+ substances. The Russian inventory, which is expected to be published by the end of 2020, will be forwarded to the Eurasian Economic Commission to form a common Eurasian substance Register.
GPC Group summarizes three scenarios for companies that exporting to Russia:
GPC will continue to keep you updated on the news regarding the Russian inventory and TR 041.