The main document regulating the circulation of chemical products on in the territory of the Eurasian Economic Union (EAEU) (member states – Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia) is the Technical Regulation 041/2017.
What is the TR 041/2017?
TR 041/2017 often referred to as the «EAEU- REACH» – is the new EAEU Technical Regulation “On the Safety of Chemical Products” that was adopted by the decision of the Council of the Eurasian Economic Commission on March 3, 2017 and is expected to enter into force on June 2, 2021.
This technical regulation was developed in accordance with Article 52 of the Treaty on the Eurasian Economic Union of May 29, 2014, as well as taking into account the Globally Harmonized System of Classification and Labeling of Chemical Products (GHS) ”(hereinafter - GHS) regarding the establishment of:
- Classification criteria for the dangers of chemicals and mixtures for human health and the environment, as well as the dangers caused by their physicochemical properties;
- Information system elements, including labeling and safety data sheet requirements.
This technical regulation has been developed with the aim of:
- Establishing the uniform requirements for the application and execution in the customs territory of the Eurasian Economic Union (hereinafter referred to as the Union) for chemical products put into circulation in the customs territory of the Union, as well as the rules and forms for assessing its compliance, identification rules, requirements for terminology, labeling and rules for applying it.
- Protecting human life and health, property, the environment, life and health of animals and plants, preventing actions that mislead consumers (purchasers).
At the same time, in preparation for the entry into force of TR EAEU 041/2017, an inventory of substances (including mixtures) in circulation and planned for circulation in the Russian Federation is being carried out. The inventory is operated by the Ministry of Industry and Trade (Minpromtorg) of Russia.
Why is it important to notify the substances?
According to the TR 041/2017 there will be different requirements for the existing and new substances. New substances will have to be registered prior placing in the EAEU market. Existing substances will have some beneficial registration requirements. Current Russian inventory of chemicals based on the information from the registered Safety Data Sheets and does not reflect the real portfolio of the substances that are circulated on the Russian market.
That’s why it is important for manufactures / importers of the chemical products to make sure that all existing chemicals are in the inventory.
Who can notify the substances?
Only Russian established company can notify the substance. For non EAEU exporters, who are placing their chemicals in EAEU market there are two options, they can notify through their Russian affiliates or through their nominated Russian Representative (similar to the REACH Only Representative). The Russian Representative should be registered in Minpromtorg of Russia.
When to notify?
The deadline for the inventory submission is 1 May 2020.