BiH: Planned Amendments to the Regulations on the Conditions for Import and Export of Chemicals in the Republic of Srpska

A Draft Regulation on Amendments to the Regulation on Conditions for Import and Export of Chemicals has been published in the Republic of Srpska.

The current Regulation on Conditions for Import and Export of Chemicals has been in effect since 2019, and the planned amendments aim to align it with changes in the relevant European Union regulations.

Specifically, this regulation incorporates provisions from Regulation (EU) 649/2012 on the export and import of hazardous chemicals, known as the PIC Regulation.

The regulation governs the import and export of certain hazardous chemicals. Its goal is to enhance shared responsibility and cooperation in international trade of hazardous chemicals while protecting human health and the environment. It sets obligations for exporters to provide information on the safe storage, transport, use, and disposal of hazardous chemicals.

The PIC Regulation is a tool for implementing the Rotterdam Convention on the prior informed consent procedure for certain hazardous chemicals and pesticides in international trade.

The same principles have been adopted in the Republic of Srpska. The procedure for exporting or importing certain chemicals is detailed. The chemicals subject to these procedures are listed in Annex 1 of the Regulation, divided into three separate parts.

Depending on which list a particular chemical is on, the procedure to be followed for its export or import is defined:

• Part 1 lists chemicals subject to the prior notification procedure,
• Part 2 lists chemicals that qualify for PIC notification in the European Union,
• Part 3 lists chemicals subject to the PIC procedure under the Rotterdam Convention.

Annex 4 of the Regulation specifies chemicals and products whose export is prohibited.

It is important to note that special procedures for the import and export of chemicals apply only to those listed in the annexes of this regulation. This means that for the import or export of other chemicals, no special controls should be conducted during cross-border movement.

The proposed amendments to the regulation involve changes to the lists of regulated chemicals, specifically Annex 1 and Annex 4. In line with changes in the European Union, some new chemicals have been added to the lists, or there has been a reorganization of previously listed groups of chemicals (e.g., asbestos fibers).

New chemicals have also been added to the list of chemicals whose export is prohibited, as well as products containing certain chemicals (primarily mercury). For example, the export of cosmetic products or plant protection agents containing mercury or mercury compounds is prohibited.

To prepare for these changes, check today whether your chemicals are covered by the proposed amendments to the regulation. If they are, start preparing in collaboration with your suppliers or buyers to avoid delays in import or export.

You can find the Draft Regulation on the Ministry of Health and Social Welfare's website, in the Drafts section.

If you're unsure whether the chemicals you import or export are subject to special procedures, contact me at nina.pajovic@bens-consulting.eu.