BIH: How are chemicals categorized for entry into the Chemical Inventory?

I often encounter dilemmas when it comes to grouping chemicals for entry into the Chemical Inventory. Even I have them sometimes. That's when I always check what the regulations say.

But let's take a step back for a moment. Entry into the Chemical Inventory is currently conducted only in the Republic of Srpska. In the Federation of Bosnia and Herzegovina, the adoption of bylaws is expected to enable this procedure in the same way as in the Republic of Srpska.

Grouping chemicals allows for similar chemicals to be included in a single submission requesting their entry into the Chemical Inventory. This reduces the fee paid for the procedure. Also, the Ministry reviews similar documentation in one process, which shortens the procedure.

Criteria for grouping chemicals are prescribed by the Regulation on the Chemical Inventory, and they depend on the procedure by which the chemical is entered into the Inventory.

For the notification procedure (for non-hazardous chemicals or chemicals intended for general use), the criteria are prescribed by Article 6 of the Regulation. The basic condition is the same purpose.

This is the case with dishwashing detergents with different scents. However, the same purpose does not mean "general-purpose cleaning agent." Although they have many similar characteristics, dishwashing detergent, laundry detergent, and floor cleaner cannot be grouped together.

I recommend considering the physical form when grouping. Liquid and powdered laundry detergents should not be grouped together. In such cases, there are significant differences in product composition, and often in hazard classification as well.

Up to 20 chemicals can be grouped under one submission. If they are chemicals for general use, the group can only consist of chemicals from one manufacturer.

For chemicals in the group, a dossier and accompanying documentation must be submitted for each chemical. In some conditions, it is possible to submit a single dossier for multiple chemicals.

Let's now look at the criteria for grouping chemicals according to the registration procedure (e.g., industrial hazardous chemicals). They are prescribed by Article 12 of the Regulation.

Chemicals can be grouped if they have:

• the same purpose,
• the same hazard classification and the same components determining the hazard classification,
• a composition that differs in the type of pigment or additive, or components that do not affect the hazard classification.

Besides purpose, which is the basic condition for notification, here hazard classification and, to some extent, composition must also align.

A registration group can consist of, for example, sodium hydroxide solutions from different manufacturers.

One registration request can be submitted for up to 20 chemicals, but since the criteria are stricter, it's harder to group a larger number of chemicals.

In this case, a separate dossier and accompanying documentation must be submitted for each chemical in the group. A single dossier can be submitted under conditions prescribed by the Regulation.

In the authorization process, it is not possible to group chemicals.

We still need to look at the financial aspects of grouping chemicals.

Fees are prescribed by the Regulation on Fees Related to Chemicals. It is also prescribed that when grouping chemicals, the basic fee amount increases by 20% for each subsequent chemical in the group. This leads to significant savings.

For notification of one chemical, the fee is 50 KM. The fee for entering a group of four chemicals into the Chemical Inventory is 80 KM. For individual notifications of four chemicals, the fee would be 4 x 50 KM, or 200 KM in total.

For registration of one chemical, the fee is 200 KM. In the case of a group of four chemicals, the fee is 320 KM. For individual registrations of four chemicals, the fee would be 4 x 200 KM, or 800 KM in total.

Keep in mind the criteria for grouping chemicals when preparing documentation for entry into the Chemical Inventory. Grouping can bring you significant savings. However, if grouping is not in accordance with the prescribed criteria, resolving your submission will not be straightforward. It can also result in the rejection of the notification or request as incomplete. And that costs you, both in money and time.

If you're unsure whether and how you can group your chemicals, we can help. Contact us at nina.pajovic@bens-consulting.eu.