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Deadline for Notification to Russian Inventory is extended to 1st Aug. 2020, this will later form part of EURASIA Inventory

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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On August 1, 2025, the Eurasian Economic Commission (EEC) Council approved two essential “second-level” documents under the EAEU Technical Regulation “On Safety of Chemical Products” (TR EAEU 041/2017):

Procedure for forming and maintaining the EAEU register of chemical substances and mixtures
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These procedures were developed by the EEC in collaboration with all EAEU Member States — Armenia, Belarus, Kazakhstan, Kyrgyzstan, and Russia—to standardize chemical product management across the EAEU.

Purpose of the Procedures

The EEC Council’s decision aims to implement the provisions of TR EAEU 041/2017, ensuring:

A unified register of chemical substances and mixtures circulating in the EAEU
Standardized notification procedures for new chemical substances
Up-to-date information for market participants on chemical products
Reduced financial and time costs for preparing documents, including safety data sheets and conformity assessment

Implementation through the EAEU Integrated Information System

The Unified Register will be maintained using the EAEU integrated information system, enabling a common and streamlined process across all EAEU member states. This digital system ensures accurate and timely updates for companies and regulatory authorities.

Importance for TR EAEU 041/2017

Approval of these procedures is a key condition for enacting the EAEU Technical Regulation “On Safety of Chemical Products” (TR EAEU 041/2017). Once fully implemented, the regulation will strengthen chemical safety standards across the EAEU, providing legal certainty and harmonized rules for all companies operating in the union.

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Ukraine aligns its chemical policy with the EU

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Since Ukraine became an EU candidate in June last year the country has been working on aligning it...

Since Ukraine became an EU candidate in June last year the country has been working on aligning its chemical policy with EU REACH. Last December the country published the law on chemical safety and management of chemical products in accordance with the EU legislation.

Furthermore, Ukraine has issued a draft resolution in accordance with the 1998 EU Directive on protection of employees from harmful chemicals where it lists hazardous substances prohibited for production.

Now, Ukraine is aligning its chemical regulations with the EU's CLP system. The country is set to adopt its first technical regulation on hazard classification, labelling, and packaging of chemical products this summer.

Ukraine's recent law on chemical safety and product management laid the groundwork for aligning with EU legislation, outlining basic hazard classification principles and general labelling rules. However, the proposed CLP Regulation takes it a step further by introducing comprehensive rules to protect human health and the environment from hazardous chemicals, ensuring their free circulation in the domestic market, and establishing a national list of approved hazard classifications and labelling elements.

The Ministry of Environmental Protection and Natural Resources anticipates that most aspects of the Regulation will come into effect on 9 July 2023. However, certain elements, including identifiers for dangerous chemical products, alternative substance names, packaging and storage requirements, and requests for new information, are expected to be implemented by 29 June 2024.

To gather feedback, the draft CLP Regulation is currently open for comments via the WTO until 20 June, allowing stakeholders to contribute to the regulatory process.