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 nomination of chemical substances to the Russian Inventory has now closed.
GPC are delighted to state that during the Inventory nomination our company has nominated +350 substances from 20 different companies!
To see what are the next steps regarding the inventory - please see our "Three scenarios of compliance strategies in EAEU after 1st of August 2020" on the Eurasia homepage.
In 2017, the Council of the Eurasian Economic Commission (EAEU Commission including Russia, Belarus, Kazakhstan, Kyrgyzstan & Armenia) adopted the Technical regulation 041/2017 ‘on safety of chemical products’ .
This Regulation is expected to come into force on 2nd of June 2021.
The process of implementation of the TR 041/2017 includes a creation of national chemical inventories that are later expected to be merged into a common Eurasian chemical inventory. The inventory is supposed to include chemicals and mixtures in circulation and those intended for circulation in the territory of the Eurasian Economic Union. At present, only the Russian Federation has an established inventory notification process through an online Information Exchange Platform (GISP).
The deadline for the Russian national Inventory notification was initially set to 1st May 2020, however, due to the current COVID-19 situation; this deadline has now officially been extended to 1st of August 2020.
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