If you do business with chemicals in Bosnia and Herzegovina, the first question is always the same: is the substance allowed on the market, and are there any bans or restrictions?
The answer is not straightforward. Regulations are fragmented, the entities are regulated differently, and EU legislation serves as guidance but does not apply automatically.
That is why I have prepared a practical guide to help you check the status of any chemical step by step.
Step 1: Check the entity where you place the chemical on the market
The first question is always: in which entity will the chemical be sold or used? The reason is simple:
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Republika Srpska has developed regulations on chemicals and biocides that are aligned with EU legislation.
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The Federation of Bosnia and Herzegovina has a Law on Chemicals, but it is not applied due to missing by-laws.
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Brčko District still has no legislative framework; businesses mostly follow the regulations of Republika Srpska.
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Additionally, Bosnia and Herzegovina has regulations on precursors for the manufacture of narcotic drugs.
Due to regulatory differences, the status of a chemical may differ between entities. That is why this is the starting point.
Step 2: Check the status of substances in Republika Srpska
In Republika Srpska, specific conditions are defined for certain substances under chemicals and biocides regulations. Below is a practical order of checks:
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Check whether the substance is listed in the List of restricted and prohibited chemicals, which is part of the Rulebook on Restrictions and Prohibitions of Chemicals.
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If it is listed, check the conditions: is the chemical completely prohibited for certain uses, or are there restrictions (e.g. limited to specific uses)?
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If the substance is not on this list, check whether it is considered a Substance of Very High Concern (SVHC).
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If it is, check the obligations that apply to substances of very high concern.
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Then check whether special import (or export) procedures apply. Consult the lists defined in the Rulebook on Conditions for the Import and Export of Chemicals.
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If the substance is covered by this rulebook, verify whether the required procedures have been fulfilled.
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If the chemical you manufacture or import is a biocidal product, check whether it is included in the list of permitted active substances or the list of prohibited ones, and ensure that all specific requirements are met.
This step is most useful for companies operating in Republika Srpska, but it is also very informative for other companies, as it prepares you for upcoming obligations that you may not yet have.
Step 3: Check the status of substances in the Federation of Bosnia and Herzegovina
Currently, the assessment must be carried out according to older regulations on poisons, but additional restrictions also apply to industrial chemicals:
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Check whether the substance is included in the List of Poisons Allowed to Be Placed on the Market in the Federation of Bosnia and Herzegovina. This check is also required for biocides.
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If it is listed, you must obtain permits for the trade of poisons.
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If not, check the Decision on the Prohibition or Restriction of the Import, Production, Marketing, and Use of Certain Hazardous Industrial Chemicals in the Federation of Bosnia and Herzegovina
(“Official Gazette of the Federation of BiH”, No. 52/16 and 47/19). -
Substances regulated by this decision may be subject to special conditions.
Step 4: Check whether additional requirements apply in Bosnia and Herzegovina
Consult your customs broker and check whether special requirements apply based on the customs tariff code. Special permits may be required under the Decision on the Classification of Goods into Export and Import Regimes.
Then verify whether the substance is considered a precursor for the manufacture of narcotic drugs. Such substances are subject to special rules.
Step 5: Assess the real possibility of placing the chemical on the market
Only after a thorough review can you conclude whether a chemical is allowed, whether restrictions apply, and whether additional permits are required. Only then can you decide whether to place a chemical on the market.
Very important note: EU restrictions, bans, and other conditions for certain substances do not apply automatically in Bosnia and Herzegovina. However, these regulations should still be monitored, as they allow you to anticipate future obligations. These rules always eventually reach Bosnia and Herzegovina.
As you can see, checking the status of a chemical in Bosnia and Herzegovina cannot be done in a single step. It requires knowledge and understanding of numerous local regulations. I hope this guide helps you in your daily work.
If you still need assistance, feel free to contact me at nina.pajovic@bens-consulting.e
Picture from pixabay.com
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