Do I need a permit to import chemicals into the Federation of Bosnia and Herzegovina?

Inconsistent chemical regulations in Bosnia and Herzegovina often cause practical issues. The same chemical can be treated differently in the two entities, posing challenges for importers.

We know that chemicals imported into Republika Srpska must be registered in the Chemical Inventory before import. In the Federation of Bosnia and Herzegovina, this procedure outlined by the Chemicals Act has yet to be implemented.

However, regulations on poisons are still in effect in the Federation of Bosnia and Herzegovina. Therefore, the obligations of a chemical importer in the Federation primarily depend on the product's composition.

The importer is responsible for the safety of the products they place on the market, so before doing so, they should:

• check the product's composition,  
• conduct a hazard classification,  
• prepare a safety data sheet,  
• ensure label compliance.

When checking the composition, it is crucial to determine if the product contains substances from the List of Poisons Allowed for Trade in the Federation of Bosnia and Herzegovina. This determines the level of obligations the importer has.

If it is determined that the product contains poisons, the importer must obtain approvals from the Federal Ministry of Health, specifically: 

• approval for conducting chemical trade activities and  
• approval for importing products containing poison.

These are two administrative procedures that must be completed before importing a product and can be quite demanding. To obtain approval for the activity, the importer must have storage space and meet strict requirements, and for importing a specific product, they need to:      

• submit a safety data sheet,    
• ensure proper product labeling,    
• apply for a sanitary inspection of the shipment during the import process. 

In addition to the application of poison regulations, certain dangerous chemicals may have additional obligations, so it is necessary to check if there are any restrictions or bans for some substances.

If the product does not contain poisons, the import process is significantly simpler. In this case, the importer must:      

• possess a safety data sheet (SDS) compliant with current regulations,       
• ensure proper product labeling in one of the official languages of BiH,       
• complete customs and sanitary procedures.

For importing such products, no special import permit is required, but sanitary or market inspections may occur. These products are subject to consumer protection regulations as well as general use item regulations.

For biocidal products in the Federation of Bosnia and Herzegovina, there is no specific procedure, but poison regulations and other regulations still apply to these products.

In the near future, the implementation of the Chemicals Act is expected to begin. Until then, the import procedure for chemical products in the Federation of Bosnia and Herzegovina depends solely on whether the product contains poisons or not.

Products containing poisons require special permits, while the import of products without poisons is unrestricted. In both cases, it is necessary to ensure that the product has proper labeling and a safety data sheet.

And one more thing: if the products imported into the Federation of Bosnia and Herzegovina are also to be marketed in Republika Srpska, then it is necessary to meet the requirements applicable in that entity.

All these are reasons why the first thing you should do when planning an import is to check regulatory obligations. If you don't have the time or don't know where to start, we can do it for you. Contact me at nina.pajovic@bens-consulting.eu.