Today, I will write in a little more detail about the different procedures for entering chemicals into the Chemical Inventory.
As you already know, the entry of chemicals into the Chemical Inventory is prescribed by the Law on Chemicals in both the Republika Srpska and the Federation of Bosnia and Herzegovina.
The Chemical Inventory is an overview of chemicals that are on the market of the Republika Srpska, i.e. the Federation of Bosnia and Herzegovina.
In the Republika Srpska, the Inventory was established back in 2009. Since then, chemicals have been continuously entered into the Inventory. The Ministry of Health and Social Protection of the Republika Srpska periodically publishes an Extract from the Chemical Inventory on its website. According to data from April 3 of 2023, more than 6,500 chemicals, or groups of chemicals, have been entered into the Chemical Inventory so far.
In the Federation of Bosnia and Herzegovina, the entry of chemicals has not yet begun, and is conditioned by the adoption of an appropriate by-law. It is expected that the procedures in the Federation of Bosnia and Herzegovina will be aligned with those in the Republika Srpska.
In the Republika Srpska, the Chemical Inventory Rulebook stipulates that chemicals are entered in the Chemical Inventory according to the notification, registration or authorization procedure. The procedure applies to both substances and mixtures.
How do you know which chemical is subject to which procedure?
The notification procedure applies to the following chemicals:
- chemicals that are not classified as hazardous,
- chemicals used for the purpose of research and development of products and processes,
- laboratory chemicals for the purposes of scientific research and development, usually in quantities up to 1t per year,
- chemicals intended for general use,
- chemicals contained in a product, in special cases.
The following are subject to the registration procedure:
- hazardous chemicals intended for industrial, professional and institutional use,
- laboratory chemicals for the purposes of scientific research and development if classified as hazardous, usually in quantities exceeding 1t per year.
Authorization applies to:
- substances of very high concern in quantities exceeding 1 kg per year,
- mixtures containing substances of very high concern in quantities exceeding 10 kg per year,
- other chemicals that are determined to pose an unacceptable risk to human health and the environment.
Depending on the type of procedure, the documentation that needs to be prepared for certain chemicals differs. Also, different fees are prescribed for certain procedures. For example, the application fee is 50 KM (approx. €25,6) for a chemical, while the registration fee is 200 KM (approx. 102,3). Details are defined in the Regulation on the amount of fees related to chemicals.
I would like to remind you once again that the procedure for amending the Regulation on the Inventory of Chemicals is underway in the Republika Srpska. The changes also apply to the application of certain procedures to different types of chemicals. See all the details of the planned changes in this text.
I hope that the entry in the Inventory of Chemicals is now clearer to you. However, it is not always easy to choose the appropriate procedure. If you need help with that, contact me at nina.pajovic@bens-consulting.eu.
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