What should you pay attention to when importing sample chemicals from the USA to Slovenia?

An interesting question came to my email address: 

“The development department is reaching out to you with a request for assistance in importing chemicals (cleaners) from the USA. These are sample quantities (5 times 0.5 liters) that we will use for a one-time test of the cleaners' impact on our products. Please advise and prepare the necessary procedures for import.”

Perhaps my response will be interesting for you as well, so I am sharing it with you.

When importing chemicals from third countries (countries outside the EU), the following must be considered:

1.    REACH registration of individual substances: 

In this specific case, it is NOT applicable because it involves the import of less than 1 ton of substances per year.

2.     PCN notification of hazardous mixtures (notification of chemicals to EU Poison Centers)

In this specific case, it is NOT applicable because the chemicals will be used for one-time testing or for scientific research and development, which means any conducting of scientific experiments, analysis, or chemical research performed under controlled conditions.

3.     ISK notification of hazardous chemicals (notification to the Slovenian Chemicals Office)

In this specific case, it is NOT applicable because these are chemicals intended exclusively for testing with the use of only a few individuals and are produced or imported annually in quantities less than 100 kg.

4.     Listing of classifications and labeling in accordance with the CLP Regulation (C&L notification)

In this specific case, it would be necessary to list the classifications and labeling of hazardous substances that affect the classification of mixtures. The number of substances that would need to be notified was determined when we created safety data sheets in accordance with EU legislation.

5.    Safety Data Sheets (SDS)

Safety data sheets must be made in accordance with EU legislation. In this specific case, the Slovenian importer received safety data sheets made in accordance with American legislation. Based on these safety data sheets, we created safety data sheets for them in accordance with EU legislation (REACH).

When importing  chemicals into the EU, it is necessary to ensure a safety data sheet made in accordance with EU legislation, in which the EU classification and labeling of the chemical is determined. When importing sample quantities of chemicals, it is necessary to ensure only the listing of classifications and labeling of hazardous substances.

If you have any questions regarding the import of chemicals into the EU, I am always available at the email address: simona.miklavcic@bens-consulting.eu.