In 2017, the Eurasian Economic Union (EAEU), consisting of Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia, published a new Technical Regulation (TR) No 041/2017, on the safety of chemicals products, or also known as Eurasia-REACH. The new TR requires legal entities manufacturing or importing substances and mixtures into the EAEU countries at any tonnages, to register these chemicals at the respective competent authorities in the EAEU member states. The first step in the implementation process is the compilation of national chemical inventories via an inventory notification process.

Eurasia REACH itself has not been enforced yet, with its secondary legislation still in the draft phase. As it stands now, the legislation is expected to enter into force in June 2021. However, Russia, as the first member state, has started with the notification process for compiling a national chemical inventory.

The inventory notification process

Since November 2019, Russia has been compiling a national inventory to list existing chemicals on the Russian market. The initial deadline for the Russian inventory notification process (1 January 2020) has been meanwhile moved to 1 August 2020. The notification process is not obligatory, however, all chemicals notified on the inventory, will be treated as “existing chemicals” in the EAEU after TR No 041/2017 has entered in force. Chemicals not listed, will be regarded new chemicals in the EAEU and require a comprehensive study of their hazardous properties and a chemical safety report during notification (“registration”). This needs to be carried out before the chemicals are marketed in Russia.

Who can notify?

Manufacturers, importers and nominated representatives (NR) based in an EAEU country can notify substances and mixtures in the inventory. In case of NR, each importer in the EAEU would become a downstream user whose compliance obligations are covered by the representative.

Where to notify?

Currently, notifications can be submitted for Russia on the Russian governmental industry information exchange platform (GISP).

What substances to be notified?

The inventory notification applies to all existing chemicals or those planned for use on the Russian market, with certain exception, such as:

  • Pesticides
  • Medicines, incl. veterinary medicines
  • Food products
  • Perfume and cosmetic products
  • Chemical products intended for, or resulting from, research
  • Minerals that have not been chemically altered.

Notification applies to all substances on its own or in mixture at a concentration higher than 0.1 wt%. For polymers, this applies to monomers, stabilisers, additives and polymerisation initiators.

Our Eurasia REACH services

Together with our partner, we can offer you the following chemicals regulatory services on the EAEU market:

  • Notifying chemicals in the EAEU inventory
  • Classification and labelling
  • Nominated representative services through our local partner
  • Communication with the competent authorities
  • Services related to the future registration obligations under Eurasia REACH