The deadline for listing Russian chemicals is May 1, 2020!All important problems solved

The five countries of the Eurasian economic union (EAEU), Armenia, belarus, kazakhstan, kyrgyzstan and Russia, are actively promoting the development of REACH, officially known as TR EAEU 041/2017, also known as Eurasia-REACH.

To better manage chemicals in EAEU, MINPROMTORG, the ministry of industry and trade, Russia's governing body, opened up the list of chemicals to Russian companies in November 2019.All chemicals circulating in the EAEU can be added to the list of existing substances by submitting relevant information to the authorities.The directory will continue to be used under TR EAEU 041/2017 and relevant regulatory response will be carried out according to the material inclusion.

1.       Are all chemicals listed?

all chemical products in circulation in the eeu can be submitted.In addition to the substance itself, if the substance contains more than 0.1% (mass percentage) of impurities or additives, relevant information should also be submitted for inclusion in the directory.

2.       How do mixtures get cataloged?

Currently, a mixture is required to submit component information, and any component exceeding 0.1% (mass percentage) is required to submit information for inclusion in the catalog.

3.       How do polymers get listed?

Monomers and other additives, such as initiators, plasticizers, etc., are required to be submitted for inclusion in the list if they exceed 0.1% (mass percentage).

4.       Who can submit material information?

Only companies in Russia are currently allowed to submit.Production enterprises outside Russia may, by appointing representatives, entrust enterprises inside Russia to submit relevant materials.If the importer wishes, the importer may submit the relevant information on his behalf.

5.       Why do enterprises carry out directory listing work?

Once the listing is confirmed and EAEU 041/2017 is implemented, all chemicals not listed on the list will be considered new.New and conventional substances have different registration processes and data requirements.According to the information available at present, the off-list new substances need to fulfill the notification and registration obligations of new substances, and there are data requirements for physical, chemical, toxicological and ecological toxicological substances;Existing substances have a registration obligation, and the registration requirements for existing substances are relatively lower than those for new substances.Therefore, we encourage enterprises that export chemical products traded by the Eurasian economic union to sort out the list of substances as soon as possible and submit materials for substances, additives and impurities exceeding 0.1%, so as to reduce the requirements of follow-up regulations.

6.       Which substances are exempt under the regulations?

• research purpose

• unchemically modified mineral resources

• pharmaceutical and veterinary products

• perfumes and cosmetics

• chemical products that make up ionizing radiation sources

• food, bioactive and nutritional additives and animal feed

• products contained in finished products (under certain conditions, for example, not releasing harmful substances)

• disposable wastes from the production and consumption of chemical products

• chemicals that fall within the scope of customs transit procedures through the territory of the Russian federation

7.       The deadline for listing

Last week's deadline for official Russian listing was May 1, 2020.As the submitted materials may not conform to the standard, considering the time cost of repeated modification, we suggest the enterprise to collect relevant materials as soon as possible and submit the work.

                                                                                                        By Yangyang