eurasia reach: what’s next after...page 1 eurasia reach: what’s next after inventory process...
TRANSCRIPT
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Page 1
Eurasia REACH: what’s next after
inventory process
December 11th, 2020
Chemical Watch Expo
Virtual Event
TR041 (“Eurasia REACH”) and GOST-300333 – major hurdles for the industry. How to comply?TR041 (“Eurasia REACH”) and GOST-300333 – major hurdles for the industry. How to comply?TR041 (“Eurasia REACH”) and GOST-300333 – major hurdles for the industry. How to comply?
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Workshop Presenter
OLESIA POCHAPSKASenior Manager
REACHLaw Finland
mailto:[email protected]
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Agenda
1. REACHLaw in Brief
2. Eurasia REACH (TR041) Recap
3. Chemical inventory in Russia and the EAEU: transitional results and current activities
4. Mandatory Chemical Safety Passports
5. Registration Requirements
6. Main uncertainties and next steps
7. Contact Information
8. Q&A Session
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1. REACHLAW IN BRIEF
2. EURASIA REACH RECAP
3. CHEMICAL INVENTORY IN RUSSIA/EAEU
4. MANDATORY CHEMICAL SAFETY PASSPORTS
5. REGISTRATION REQUIREMENTS
6. MAIN UNCERTAINTIES AND NEXT STEPS
7. CONTACT INFORMATION
8. Q&A SESSION
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UK REACH / CLP *
EU REACH / CLP
TURKEY KKDIK / SEA / GBF
EURASIA “REACH”
KOREA REACH
CHINA “REACH”/ GHS
* Upon entry into force
We Specialize in Chemical Regulatory
Compliance and
Sustainability
Providing Support for REACH and “REACH-Like” Chemical
Regulations Globally
INDIA “REACH”*
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Page 6
About
• Established in Helsinki, Finland 2006
• Offices in six (6) countries
• Multidisciplinary team - Business, Legal & Technical: Toxicologists,
Eco-toxicologists, Chemists, Socio-econ. analysts and Environmental specialists
• 20+ local partners in Europe, Asia, Latin-America & USA Support in
10+ different languages
• Major industries served: Oil, Chemicals, Specialty Chemicals, Metals, Aerospace
sector, Pulp & Paper and Other downstream users (DU) industries, etc.
• More info at: www.reachlaw.f i
http://www.reachlaw.fi/
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REACHLaw ServicesEURASIA “REACH” Services (incl. Russia)
1. Inventory Notification
2. Nominated Representation (through REACHLaw OOO in Moscow, Russia)
3. Chemical Safety Passports
4. Registration of Existing Chemicals
5. New Substance Notification
6. Legal & Technical Services
7. Legislation Monitoring Service
8. Consulting
9. Training …and more
Name:REACHLaw OOO
Address: 3
rdGolutvinski pereulok,
house 11, building 6,Moscow, 119180The Russian Federation
Registration No. / Tax ID: 9706002574
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REACHLAW TALKS on YouTubeB
EN
AN
DE
RS
ON
Follow us on YouTube! REACHLAW TALKS is now live!
https://www.youtube.com/channel/UCrivV4JsJ33EsF8FbJECeug
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1. REACHLAW IN BRIEF
2. EURASIA REACH RECAP
3. CHEMICAL INVENTORY IN RUSSIA/EAEU
4. MANDATORY CHEMICAL SAFETY PASSPORTS
5. REGISTRATION REQUIREMENTS
6. MAIN UNCERTAINTIES AND NEXT STEPS
7. CONTACT INFORMATION
8. Q&A SESSION
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Eurasia REACH Recap
Overview
• Technical Regulation of Eurasian Economic Union (EAEU) on Safety of chemical products (TR041/2017) approved on March 3rd 2017 → Commonly called “Eurasia REACH”
• EAEU-level horizontal regulation covering the following countries: 1. Russia
2. Belarus
3. Kazakhstan
4. Armenia
5. Kyrgyzstan
• Official commencement date - 2nd June 2021
• New draft EEC Decision to postpone the commencement date to 30th November 2022 …
• 2nd tier (implementing regulations) have not been approved …
Note to keep in mind: Technical Regulation on Safety of chemical products approved on October 7th 2016 (Decree No. 1019) →
“Russia REACH” → Russia’s national-level law was supposed to enter into force – 1st July 2021 (end of June 2019 → revoked!)
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• EEC Decision Draft on amendments to the Decision of the Council of the
Eurasian Economic Commission of March 3rd 2017 No.19
• EEC Decision Draft from 29th Sep 2020
• Order of the formation and management of the inventory of chemicals
and mixtures
• Order of the new substance notification
• The Decision of the EEC Board on transitional provisions of the technical
regulation of the Eurasian Economic Union on the safety of chemical
products (TR EAEU 041/2017)
Eurasia REACH Recap
List of 2nd Tier Legislation*
* 2nd Tier Legislation → https://docs.eaeunion.org/ria/ru-ru/0102992/ria_29052018 https://docs.eaeunion.org/ria/ru-ru/0104253/ria_29092020
https://docs.eaeunion.org/ria/ru-ru/0102992/ria_29052018https://docs.eaeunion.org/ria/ru-ru/0104253/ria_29092020
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Eurasia REACH Recap
News: delayed entry into force?
• Commission Draft Decision
– Proposal to shift commencement date to 30th
Nov 2022
• Explanatory Note (reasoning)
– More time needed due to 2nd tier delay
• 2nd tier to be finalized during 2020-2021
– Issues due to Covid
– More time needed for resolving CBI disclosure
issues addressed heavily by the industry
• Background information document
• Questionnaire (Public Consultation)
– Closed on 28th Oct 2020
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1. Preamble
2. Chapter I: Application area
3. Chapter II: Basic Concepts (Definitions)
4. Chapter III: Requirements for classification of
chemical products
5. Chapter IV: Rules for the identification of
chemical products
6. Chapter V: Classification requirements
7. Chapter VI: General safety requirements
8. Chapter VII: Requirements for labelling of
chemicals
9. Chapter VIII: Requirements for precautionary
labelling
10. Chapter IX: Requirements for SDS
11. Chapter X: Ensuring compliance with the
Regulation
12. Chapter XI: New substance notification
13. Chapter XII: Evaluation of compliance
14. Chapter XIII: Common sign for Labelling products
in the union
15. Chapter XIV: Enforcement
16. Annex 1: Exemptions
17. Annex 2: Allowed concentration limits of
hazardous substances in chemical products
18. Annex 3: CSR structure
19. Annex 4: Concentration limits for restricted
chemicals in chemical products
20. Annex 5: Registration application form (template)
21. Annex 6: Certificate for record-keeping
registration
22. Annex 7: Certificate for permitted registration
Eurasia REACH Recap
Structure of the Legal Text of Eurasia REACH
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Eurasia REACH Recap
Scope
All chemical products: substances or mixtures placed on the EAEU market
are in scope of the TR041
Identification rules - so-called “0,1% w/w rule”
“All substances, including potential additives, impurities and etc.
present at a concentration of more than 0.1% (w/w) in chemical products
have to be identified”
Exemption of chemical products placed in the EAEU below 1t/year is
planned to be decided by the 2nd June 2028 …
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Eurasia REACH Recap
Exemptions?
TR041 ANNEX 1 EXEMPTIONSScientific and research purpose
Mineral resources unless chemically modified
Pharmaceutical and veterinary products
Cosmetics
Chemical products constituting a source of ionizing
radiation
Food & additives and feed products
Products included in manufactured articles (with certain
conditions, e.g. hazardous substances are not released)
Waste subject to disposal/recycling
Chemical products in-transit
PARTIAL EXEMPTIONSChemical products under other technical
regulations of the EAEU are exempted from
the future registration requirements under
TR041, but have to fulfill C&L and Chemical
Safety Passport requirements under TR041
POTENTIAL EXEMPTIONS ?Biocides …
GOST 30333-20XX EXEMPTIONS ?Additional exemptions to be added to
TR041 in line with the new GOST 30333-
… ?
OTHER EXEMPTIONS ?Pesticide formulations …
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• On the 23rd of July, upon request of
Minpromtorg Russia, CIS Center organised an
online panel discussion in relation to biocides under TR041
• The participants of discussion: Minpromtorg, Rospotrebnadzor, CIS Center and
industry representatives
• The discussion was held around inclusion of biocidal products in the list of
exemptions under TR041
• The following decision has been reached:
• Rospotrebnadzor will prepare scientific justifications and applicable wording
(definitions) to be used in the potentially upcoming amendments of TR041
• CIS Center wil be taking this information into account (together with the requested
amendments by Kazakhstan) in the review process of TR041
Eurasia REACH Recap
Biocides to be potentially exempted ? …
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Eurasia REACH Recap
Banned and Restricted Substances
• Restricted substances are specified in
the Annex 7 to the Draft Order on Inventory
formation
• Permitted registration is applicable
• Banned substances will be published on the website of EEC
• Separate Decision by the EEC (not yet known)
• In the version_1 30 substances in the Annex 7 “Banned Substances”
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• Manufacturer • Definition in the Annex 9 of the EAEU Treaty: means a legal entity or a natural person registered as an
individual entrepreneur, including foreign manufacturers, engaged, on their own behalf, in the
manufacture or manufacture and sale of products and responsible for their conformity to technical
regulations of the Union
• Importer• Definition in the TR041: a resident of the member state of the EAEU, who has entered into a foreign trade
agreement with a non-resident member of the EAEU for the importation of chemical products into the
customs territory of the EAEU, places chemical products on the EAEU market and is responsible for product
compliance with the requirements of this technical regulation
• Nominated Representative (“Authorised Representative”)• Definition in the Annex 9 of the EAEU Treaty: means a legal entity or a natural person registered as an
individual entrepreneur, duly incorporated in accordance with the legislation of a Member State on its
territory, acting on behalf of a manufacturer, including foreign manufacturers, under an agreement when
carrying out conformity assessments and releasing products into circulation on the territory of the EAEU
and responsible for non-compliance of such products with the technical regulations of the EAEU
Eurasia REACH Recap
Roles in the regulation
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Eurasia REACH Recap
Nominated (Authorised) Representative
An official agreement between NR and the Manufacturer is
mandatory.
The agreement has to contain among other the following clauses:
1. Authorisation to act on behalf of the Manufacturer in relation to
regulatory conformity assessment and placement of chemical
products on the EAEU market …
2. Liability issues to be clearly stated (according to the TR041 NR is
responsible for any non-compliances, incl. Chemical Safety
Passports!) …
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• Inventory process – non-mandatory (but recommended…)
• Timeline: by 1st August 2020 in Russia
• Transitional Inventory: https://gisp.gov.ru/cheminv/pub/app/search/
• Chemical Safety Passport (including C&L) - mandatory
• Timeline: required once TR041 enters into force
• New Substance Notification – mandatory for new chemicals
• Timeline: required once TR041 enters into force and before chemical product containing
new substance is placed on the EAEU market
• Registration of chemical products - mandatory
• Timeline: depending on whether your product a substance or a mixture and according to
the applicable tonnage band
Eurasia REACH Recap
Main requirements under TR041
https://gisp.gov.ru/cheminv/pub/app/search/
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1. REACHLAW IN BRIEF
2. EURASIA REACH RECAP
3. CHEMICAL INVENTORY IN RUSSIA/EAEU
4. MANDATORY CHEMICAL SAFETY PASSPORTS
5. REGISTRATION REQUIREMENTS
6. MAIN UNCERTAINTIES AND NEXT STEPS
7. CONTACT INFORMATION
8. Q&A SESSION
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Chemical inventory in Russia & EAEU
Transitional Results and Ongoing
Activities
• Transitional inventory is still work-in-progress
– Inventory will be updated in the end of 2020 … more substances will be added from re-submission results and
those checked/accepted after 15th June 2020
– Combined EAEU Inventory will be published in 2021 …
– Chemical inventory for mixtures will start formation based on the mixture registration after 2027 …
• According to the CIS Center, Minpromtorg has received 500 000 chemical substances out of
which 80 000 were unique chemicals
– Most of the chemicals were submitted after the 1st and 2nd deadline extensions..
– CIS Center has pointed out a number of mistakes in inventory notification files, especially emphasized non
acceptable information submitted only in English language and C&L according to CLP
• Transitional Inventory in Russia
https://gisp.gov.ru/cheminv/pub/app/search/
– Re-submissions for additional information closed on 23rd
Oct 2020)
https://gisp.gov.ru/cheminv/pub/app/search/
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COMMON EAEU CHEMICAL INVENTORY WILL BE
PUBLISHED IN 2021 …ESTIMATED FEBRUARY 2021 ?
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Chemical Inventory in Russia
Late inventory notification for substances missing from the inventory
Late Inventory Notification: Until 2nd June 2023 substances that are not
listed in the inventory, but can be proved to have been placed in the
EAEU before Eurasia REACH entered into force, can be added to the
inventory without going through the NEW SUBSTANCE NOTIFICATION
procedure (similar to Lead Registration in the EU REACH).
SUFFICIENT PROOF AND WHAT WOULD BE THE PROCEDURE TO BE
CONFIRMED IN 2021
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1. REACHLAW IN BRIEF
2. EURASIA REACH RECAP
3. CHEMICAL INVENTORY IN RUSSIA/EAEU
4. MANDATORY CHEMICAL SAFETY PASSPORTS
5. REGISTRATION REQUIREMENTS
6. MAIN UNCERTAINTIES AND NEXT STEPS
7. CONTACT INFORMATION
8. Q&A SESSION
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Chemical Safety Passport
What is GOST 30333?
• Chemical Safety Passport = CSP will be the
most important compliance document under
TR041
• GOST 30333-2007 is a valid standard applied
when developing a chemical safety
passports - “Chemical Safety Passport.
General Requirements.” valid in Russia (and
the EAEU) from 2009
– Chemical Safety Passport = CSP
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Chemical Safety Passport
Mandatory CSP – why and how?
TR041 – Eurasia REACH GOST 30333-2007 Guidance P 50.1.102-2014
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Chemical Safety Passport
GOST 30333-2007 and other related GOSTs are to be updated
• GOST standards under review and to be updated during 2020-2021
– GOST 30333–2007 ”Chemical Safety Passport. General requirements”
– GOST 32419–2013 ”Classification of chemical products. General requirements”
– GOST 31340–2013 ”Precautionary Labelling of chemical products. General requirements”
• GOST 30333-2007 update is supposed to reflect TR041 (Eurasia REACH) requirements
– CSP registration as such will no longer be required at the competent authority, however CSP will be
provided to the registration authority during chemical product registration according to the applicable
registration deadline set by TR041, where CSP will serve as a ”registration dossier”
• Even after update most of the requirements of GOST 30333-2007 will migrate to the
new GOST 30333-20XX → the procedure will not become easier
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Chemical Safety Passport
Scope
Under GOST 30333-2007, CSP is required for chemical
substances, chemical mixtures, materials and industrial waste
Under draft GOST 30333-20XX, CSP is required for commercial
products …
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Chemical Safety Passport
Current and potential exemptions
• Mineral resources (bedding state)
• Finished pharmaceutical products
• Finished cosmetic-perfumery products
• Emitting, nuclear and radioactive substances
• Finished food products
• Products manufactured according to closed
nomenclature
Note: CSP is not required for finished articles →
articles are not considered to be chemical products
• Mineral resources (bedding state)
• Finished pharmaceutical and finished veterinary
medicine products
• Finished cosmetic-perfumery products
• Emitting, nuclear and radioactive substances
• Finished food products, biologically active food
additives, food additives, finished animal feed
• Smokable and smokeless tobacco products
• Liquid for electronic system of adding nicotine
• Medical device
Note: CSP is not required for finished articles → articles
are not considered to be chemical products
Exemptions under GOST 30333-2007 Exemptions under updated GOST 30333-20XX
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Chemical Safety Passport
EU REACH SDS vs. CSP (GOST 30333-2007)EU REACH SDS GOST 30333-2007 Compliant CSP
GHS Format 16 Sections GHS Format 16 SectionsNote: more detailed information, where all mandatory subsections have
to be filled according to the competent information sources (also, see
slide: GOST 30333-2007 compliant CSP Part 2/4 )
Required for hazardous substances and mixtures Required for all chemical products (incl. non-hazardous!),
unles exempted
- Official format for the Title page
- Registration is required (for now)
- Limited Validity (3 or 5 years)
- QR code assigned by the authority after registration
- All sources have to noted in the CSP text with references and
in listed in Section 16
Exposure Scenarios -
EU member-state language is required Russian language (+ if required by specific EAEU member in
the local language)
Classification: GHS Rev.5 Classification: GHS Rev.4
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TRANSITIONAL PROVISIONS FOR CSP ARE NOT
CURRENTLY FORESEEN IN THE TR041 AND/OR 2ND
TIER LEGISLATION DRAFTS …
MEANING CHEMICAL SAFETY PASSPORT ACCORDING TO
GOST 30333 IS MANDATORY FROM TR041 DAY ONE
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1. REACHLAW IN BRIEF
2. EURASIA REACH RECAP
3. CHEMICAL INVENTORY IN RUSSIA/EAEU
4. MANDATORY CHEMICAL SAFETY PASSPORTS
5. REGISTRATION REQUIREMENTS
6. MAIN UNCERTAINTIES AND NEXT STEPS
7. CONTACT INFORMATION
8. Q&A SESSION
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Registration Process Overview
Competent authorities appointed in Russia
• Minpromtorg Russia competent auhtority No.1
– Inventory formation and management of substances and
mixtures (national inventory)
– New substance notification management upon
Rospotrebnadzor expert conclusion
– Organisation and management of record-keeping and
permitted registration with conlusion of the appointed expert
organization (CIS Center?) + expert conclusion of
Rospotrebnadzor if chemcial products contain new
substances
• Rospotrebnadzor competent authority No.2
– Management of new susbtance notification and providing
expert conclusion to Minpromtorg
– Management of Permitted Registration of new susbtances:
expert conclusion preparation
Note: Due to complexity of TR041 other ministries can be
involved in course of work…
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Registration Process Overview
Options for non-EAEU manufacturersEA
EU
terr
itory
Non-E
AEU
terr
itory OPTION NO.1
Own subsidiary as
NR (or importer?)
Company A
Company A
Subsidiary
Company A
Importer
OPTION NO.2
Relying on
your importers
OPTION NO.3
Using a Nominated
Representative
Company A
Professional
Consultant as
Nominated
Representative
Pros & Cons+ CBI is safe
- Liabilities
- Up-to-date regulatory advice?
+ no direct liabilities
- CBI to be disclosed
- Dependence ….
+ no direct liabilities
+ CBI in hand of professionals
+ Up-to-date regulatory advice
- Dependence ….
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Registration Process Overview
New substance definition
• New Substance = Not Existing Substance
= Not listed in the chemical inventory
when TR041 enters into force
• There is no such concept as ”new
mixture”, therefore new substance
notifcation is relevant for substances
placed on the EAEU market either on
their own or as part of mixture
Mixtures containing New Substances in their composition will not be allowed on the
EAEU market unless New Substance Notification procedure criteria is fulfilled …
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Registration Process Overview
New substance Notification
Authority has 60
days to review
the application
If accepted
substance added
to the chemicals
inventory
New Substance
Notification
Submission of advanced
information:
• Chemical safety passport,
administrative info, Chemical
Safety Report, Substance
identification data, physico-
chemical properties, toxicology,
ecotoxicology data, uses etc
Estimated to take 2 years and cost 250 000 €
New
chemical
(Substance not
on the chemicals
inventory)
Existing
chemical
(Substance on the
chemicals
inventory)
Status: Allowed,
Restricted or Banned
Record-
keeping
registration
Permitted
registration
View Page 1/2 …
Substance
as such or
as part of a
mixture
Applicable for New Substances before placed on the EAEU market
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Registration Process Overview
Existing substance definition
• Existing Substance = Listed in the
chemical inventory when TR041 enters
into force
• Mixtures will be listed in the chemicals
inventory for mixtures only after 2027
Only existing chemicals and mixtures of existing chemicals can be registered.
New substances placed on their own or in mixtures have to go via New
Substance Notification Procedure before proceeding to Registration.
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Registration Process Overview
Registration of existing substances and mixtures
of existing substances
Existing
chemical
(Substance on the
chemicals inventory)
Substances and
mixtures
Record-keeping registration
Submission of basic information:
• Chemical safety passport, administrative
info and some chemical property
information
Registration
certificate provided
within 10 days incl.
registration number –
Validity does not
expire
Submission
deadline
Restricted
substances or
mixtures
containing such
substances (above allowed
concentration limits in
Annex 4 of Eurasia
REACH)
Applicable for Chemical Products placed on the EAEU market
Restricted substances are specified in the Annex 7 to
the “Order on Inventory Formation”
Registration
certificate provided
within 45 days incl.
registration number –
Valid for 5 years
Permitted registration
Submission of basic information:
• Chemical safety passport, administrative
info and some chemical property
information
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Registration Process Overview
Registration Submission Deadlines DRAFT …
• The registration deadlines are foreseen in the draft EEC Decision and are not yet confirmed (there are
no deadlines in the text of TR No.41).
– The dates are preliminary and indicate the start of the registration window → transitional period will apply (3
years?)
• Substance registration window: – > 1000 t/a: from the date of TR041 entering into force → deadline to be confirmed
– 100 - 1000 t/a: from 2nd of June 2023 → deadline to be confirmed
– 10 -100 t/a: from 2nd of June 2025 → deadline to be confirmed
– < 10 t/a: from 2nd of June 2027 → deadline to be confirmed
• Mixture registration window:– > 1000 t/a: from 2nd of June 2027 → deadline to be confirmed
– 100-1000 t/a: from 2nd of June 2029 → deadline to be confirmed
– 10-100 t/a: from 2nd of June 2031 → deadline to be confirmed
– < 10 t/a: from 2nd of June 2033 → deadline to be confirmed
• < 1 t/a: Substances and Mixtures may be exempted, but is currently under discussion (the decision on
exemption should be made by 2nd of June 2028)
The registration timeline is not
applicable for new substances (=not
listed in the inventory)! New
substances have to go through NEW
SUBSTANCE NOTIFICATION PROCESS
before being placed on the market!
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Mixture AB is placed on the EAEU market in
the tonnage of 10-100 t/y. Components A & B
are not placed on the market on their own,
but as part of Mixture AB only.
Registration Process Overview
Practical example of Mixture AB 10-100t/y
• Regulatory obligations applicable to Mixture AB
1. Inventory status of the components A & B once
TR041 enters into force and before Mixture AB is
placed on the market
• Components A &B are listed in the chemical inventory
• Components A & B are not banned substances in the
EAEU
• Components A & B are not restricted substances (not
in the Annex 7 to the Order of Inventory Formation)
2. Chemical Safety Passport once TR041 enters into
force before Mixture AB is placed on the market and
even before registration in this case!
3. Record-keeping registration of Mixture AB in the
period of 2nd June 2031-2nd June 2034
COMPONENT BBenzenesulfonicacid, 4-dodecyl-CAS No. 121-65-3
50%
COMPONENT A
Isopropyl alcohol CAS No. 67-63-0
50%
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Registration Process Overview
Documents/data required explained …
Testing reports(if required!)
Note: reports are not
required for chemicals
listed in the inventory
and/or those chemical
products that can be
classified by calculation
methods
Application CSP
Nominated
Representative
Agreement ?
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Page 43
1. REACHLAW IN BRIEF
2. EURASIA REACH RECAP
3. CHEMICAL INVENTORY IN RUSSIA/EAEU
4. MANDATORY CHEMICAL SAFETY PASSPORTS
5. REGISTRATION REQUIREMENTS
6. MAIN UNCERTAINTIES AND NEXT STEPS
7. CONTACT INFORMATION
8. Q&A SESSION
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Page 44
Main uncertainties and next steps
Way Forward ….
Inventory Notification
Note: ended 1st August
2020
2nd tierlegislative
acts approval
TR041 GOST standardsupdateversionsapproval
Russian finalinventorypublished
CommonEAEU
Invneotry is published
Late Inventory notifiation (based on
proof)
TR041 entering into
force
CSP is mandatory
from day one!
Substances registration (deadline
depends on the tonnage
band)
Polymer registration
Mixtureregistrationper tonnage
band
Mixtureinventory
compilationbased on
registration
Nov 2019 - Aug 2020
In Russia
Dec 2020- Spring
2021
In Russia ?
Jan – Feb 2021 ?Later in 2021 ? – 2nd
June 2023 30th Nov 2022?
30th Nov 2022 – 2nd
June 2030
2nd June 2027 – 2nd
June 2036
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Conclusions
Step to get ready for TR041 compliance
• Make an extensive list of all chemical products supplied or planned to be
supplied on the EAEU market to verify those in scope of TR041 and CSP
– Substances (0,1% w/w)
– Mixtures (0,1% w/w)
– Application area (uses)
– Tonnage per year
• Check the inventory status of each chemical: if all substances above 0,1% w/w
in your chemical products are listed in the transitional inventory https://gisp.gov.ru/cheminv/pub/app/search/
• Monitor TR041 developments and GOST 30333-20XX official approval
• CSP and New Substance Notification will be the first requirements to comply
under TR041
https://gisp.gov.ru/cheminv/pub/app/search/
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1. REACHLAW IN BRIEF
2. EURASIA REACH RECAP
3. CHEMICAL INVENTORY IN RUSSIA/EAEU
4. MANDATORY CHEMICAL SAFETY PASSPORTS
5. REGISTRATION REQUIREMENTS
6. MAIN UNCERTAINTIES AND NEXT STEPS
7. CONTACT INFORMATION
8. Q&A SESSION
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Page 47
OLESIA POCHAPSKASenior Manager | REACHLaw, Finland
Mobile: + 358 504 534 465
Office: +358 9 412 3055
E-mail: [email protected]
CONTACT US:
mailto:[email protected]
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Page 48
1. REACHLAW IN BRIEF
2. EURASIA REACH RECAP
3. CHEMICAL INVENTORY IN RUSSIA/EAEU
4. MANDATORY CHEMICAL SAFETY PASSPORTS
5. REGISTRATION REQUIREMENTS
6. MAIN UNCERTAINTIES AND NEXT STEPS
7. CONTACT INFORMATION
8. Q&A SESSION
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Page 49
Thank you!
Questions & Answers Session
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Page 50
We Specialize in Chemical Regulatory Compliance