Obligations for Chemical Importers in BiH: What Every Foreign Manufacturer Needs to Know

I've written extensively about the procedures for importing chemicals into Bosnia and Herzegovina. However, there are specific situations that require more detailed explanations.

Recently, a foreign manufacturer asked me about the obligations of their customers in Bosnia and Herzegovina. The answer might be of interest to you as well.

The first step is to determine in which part of Bosnia and Herzegovina the customer's, or importer's, headquarters is located.

If the importer is based in the Federation of Bosnia and Herzegovina, it's necessary to check whether the imported chemicals contain poisons. Obligations still exist only for poisons:

• obtaining a permit that allows the company to trade in poisons, and
• obtaining an import license for the specific chemical containing poison.

If the importer is based in the Republic of Srpska, the importer has the following obligations:

• must be registered in the Register of Chemical Manufacturers and Importers,
• must hire a chemical advisor, and
• must register the imported chemicals in the Chemical Inventory.

The listed obligations fall on the importer, while the foreign manufacturer should provide the necessary documentation and information that may be required by the relevant authorities.

However, the question was raised what happens when a foreign manufacturer has multiple importers in Bosnia and Herzegovina.

In this case, each importer must follow the prescribed procedures (obtaining an import license for poisons or registering chemicals in the Chemical Inventory).

Let's look at this with an example of an importer from the Republic of Srpska.

An importer based in the Republic of Srpska cannot freely import a chemical that another importer has registered in the Chemical Inventory. In that case, they can purchase the chemical on the domestic market from the importer who has completed the registration. If a company wishes to be a direct importer of a chemical, it must register the chemical in the Chemical Inventory for itself.

Thus, each importer is responsible for the chemicals they place on the market. Additionally, the contact details of the specific importer must be listed on the label or packaging of the chemical.

A similar situation exists in the Federation of Bosnia and Herzegovina: each importer of poisons must obtain their own import license.

And don't forget these important points:

• both hazardous and non-hazardous chemicals must be registered in the Chemical Inventory,
• an importer based in the Federation must fulfill the obligations from the Republic of Srpska's regulations if trading chemicals in that territory.

If you have additional questions about importing chemicals, feel free to write to me at nina.pajovic@bens-consulting.eu.