This article is important for all, who are exporting substances/products into the Eurasian region - Russia, Belarus, Armenia, Kazakhstan and Kyrgyzstan. There are considerable changes coming to the EAEU-REACH area, and the deadlines for making sure you keep current "benefits" are short.
As you may have heard already, Russia and other EAEU (Eurasia Economic Union) countries, i.e. Belarus, Kazakhstan, Armenia and Kyrgyzstan, are implementing an ambitious Chemical Control law.
The first step is the set-up of an inventory of all the chemical substances, produced or imported in the EAEU countries, as raw materials or as part of mixtures.
Date of finalization of this “new” inventory by the Competent Authorities in Russia is June 2020. However, the companies were expected to submit their inventories by End 2019 according to the latest information available. A deadline extension is currently being discussed.
In order to be listed on the “New Inventory of Existing Substances”, the following information has to be submitted on the substance when available: name, CAS number, GHS classification…
Note that for the submission to the inventory, you will need:
- an EAEU-based Legal Entity or you must
- appoint a ‘Nominated Representative’ in the EAEU, similarly to the ‘Only Representative’ for EU REACH.
Importantly, substances that do NOT get listed now on the Inventory will be thereafter considered as “New Substances” and this will trigger a very heavy and exhaustive NOTIFICATION OF SUBSTANCE (with many tests requested well beyond the EU REACH Registration requirements). This Notification will be required regardless of the quantity manufactured or imported into the EAEU (there is no “lower limit” for notification of new substances).
Here's something else you need to be careful with: While polymers are not requested to be listed in the inventory, their monomers and non-monomeric constituents must be listed.
If you’ve read this far you see there are lots of information to consume. So, here’s a summary of activities you need to submit to EAEU authorities:
- Notify in the inventory the substances present in your materials, and any impurities/ stabilizers/ additives present in the substances at > 0.1% (w/w), regardless of tonnage.
- Polymers: all monomers, and any additives present in polymer at > 0.1% (w/w), are to be notified to the inventory, regardless of tonnage.
- Please note they do not differentiate between intentionally or non-intentionally added substances.
- Submissions of existing substances can be made in the Russian system GISP which was opened on Nov 11th
- Q&A can be found here.
All the above shows you the importance of prioritizing activities related to the inclusion of your substances on the “new” list. Of course, you can postpone these activities, but they will be considerably more expensive and time consuming.