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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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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.

The nomination to the Russian Inventory has closed!

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:

  1. For the companies that have nominated to the Russian inventory, the next step will be the pre-registration and registration of substances in accordance with the TR 041. For now, no official information regarding per-registration and registration is available. 
  1. For those companies that did not nominate to the Russian inventory but have been exporting chemicals to the Russian market before 2nd June 2021 (enforcement of TR 041), there is an “exceptional” procedure. A substance that is not present in the Russian Inventory will be considered as “new” for the Russian market. To place that substance laboratory expertise and extensive documentation is expected to be required. The “exceptional” procedure allows a simplified nomination procedure for substances that have not been nominated to the Russian Inventory, but for which a proof can be provided that they have been circulating on the Russian market before the TR 041 enforcement (2nd June 2021).  
  1. The companies that have not nominated their substances to the Russian inventory and have not been exporting them to Russia before will be required to nominate their substance to the inventory in accordance with the TR 041. This implies that their substances will be considered “new” for the market and have to be nominated to the inventory before registration. To nominate “new” substances to the Inventory will require laboratory expertise and extensive documentation. All the details on documentation are expected to be announced at the beginning of the next year 2021.   

GPC will continue to keep you updated on the news regarding the Russian inventory and TR 041.