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 registration. For these substances, a “simplified” registration procedure is applicable. The registration is supposed to start when the Technical Regulation comes into force. Before the registration procedure starts, the registrants are recommended to prepare the Safety Data Sheet in accordance with the GOST 30333-2007. There is still no update on when the regulation will come into force. GPC will keep you updated on the registration date and deadlines. Once the authorities announce the date of the 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 (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 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.   

 

3.     If companies have missed the deadline for notifying substances to the inventory and have not been importing chemicals to Russia before the regulation comes into force.  

 Companies will need to follow the TR 041 notification and registration procedure if their substances are not presented in the Russian Inventory and they were not importing such substances before regulations implementation. In this case, substances will be considered as “new". These substances will need to follow the standardized "permissive" registration procedure (including; laboratory experiments and extensive documentation).

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