This text is intended for all those who want to sell chemicals on the Serbian market and do not know exactly how to go about it.
You should pay attention to several steps that will make it easier for you to fulfill all the obligations prescribed in Serbia for manufacturers and importers of chemicals. Let's look at a list of five key points that are essential:
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Determine whether you import or produce chemicals
Some companies involved in the trade of chemicals still do not know that they are subject to the regulations governing this area. They are surprised when the inspectorate asks them for safety data sheets or evidence that they have entered chemicals in the Register.
To avoid such a situation, check your products. This means that you must first determine the category of the product (industrial chemical, detergent, biocide, etc.) and the type of hazard. Then check with the freight forwarder whether you have additional obligations under the tariff code.
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Check if you need a chemical consultant
If you are a supplier of hazardous chemicals, you must appoint a chemical consultant. If you do not have a suitable person in your company, we can also take on this role. Such a person - if employed by the company - can be employed on an indefinite or part-time basis. However, such a person must have the appropriate professional education and have passed a consulting exam.
TIP: There are certain exceptions, i.e. companies that do not need to appoint a chemical consultant, so check whether they apply to your activity.
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Check if you need a permit
If you place chemicals on the market for certain purposes or classifications, you will need certain permits - before the first import or production.
These include particularly dangerous chemicals, biocides, dual-use goods, drug precursors and psychotropic substances, etc. The competent authorities for issuing these permits vary depending on the type of activity and chemicals.
Another note: a foreign manufacturer (or distributor) must appoint a representative or importer based in the Republic of Serbia, who will be responsible for fulfilling the prescribed obligations.
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Fulfillment of all obligations
Chemicals imported or produced in the Republic of Serbia must be registered in the Register of Chemicals. This is done from 01.01 to 31.03. for the previous year, for quantities of 100kg and more.
If you produce or import biocides, you must enter them on the provisional list or obtain recognition of the authorization for availability on the market and use, issued in accordance with EU legislation, according to the active substances that these biocides contain.
If you import or produce particularly hazardous chemicals, you also need a permit for them. It is characteristic that you must have a warehouse that meets all the requirements of the NOH.
TIP: At this stage, you must provide the appropriate documentation for the chemicals, especially the safety data sheet and label.
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Start selling
Once you have obtained the necessary permits and met all the requirements, you can start selling chemicals. Remember that you need to keep records of the chemicals you have produced or imported.
TIP: Your responsibilities do not end there. As long as the chemical you have produced or imported is on the market, you must ensure that it is used without harm to people and the environment.
I hope this short overview of responsibilities will be helpful. If you need further advice, please contact me at dragana.milovanovic@bens-consulting.eu.
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