Chemical Safety Passport (“CSP”) is a document of the Safety Data Sheet format, 16 sections, in Russian language (or in the EAEU member state language, if applicable) prepared according to the valid version of GOST 30333-.
GOST 30333- is a state standard providing guidelines how to prepare the CSP. At the moment, GOST 30333-2007 ”Chemical Safety Passport. General requirements” is a valid version of the standard. GOST standards are usually voluntary, unless a regulation or a law implements a specific standard by referencing the standard in the legal text. GOST 30333-2007 has a direct reference to it in the Technical Regulation, TR041 on Safety of Chemical Products (“Eurasia REACH”). Therefore, once TR041 enters into force, CSP according to the latest valid version of the GOST 30333- becomes mandatory.
GOST standards related to the CSP preparation and C&L of chemical products are currently under review and expected to be published and approved in 2022 (1st or 2nd quarter). The following standards will be updated to reflect Eurasia REACH requirements:
- 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”.
Final requirements related to the CSP will be available once the finalized versions of the above-mentioned standards are approved and published.
Final requirements for the CSP under Eurasia REACH will be known once GOST 30333- new version is approved.
Based on the 2007 version of GOST 30333, the information requirements for the CSP will significantly vary from EU REACH SDS also once the standard is updated. According to GOST 30333-2007, Section 3.3, all information in the CSP has to be provided from the ”competent sources” which have to be listed in the Section 16. Competent sources essentially mean those sources that are referenced in the CSP applicable GOST standards and guidance P 50.1.102-2014. In addition, each section and sub-section have to contain a reference to the sources used when providing the information. The “competent sources” requirement and references will likely remain as requirement in the new version of GOST 30333. Additionally, stating “information not available / applicable” is not generally accepted. All sections have to contain relevant correct information coming from the applicable information sources.
From the practical perspective, translation of EU SDS in Russian and adapting C&L information will not suffice for CSP to become GOST 30333- compliant, since all information has to come from the applicable “competent sources”. Therefore, a lot of information from the EU REACH SDS can not be used in the CSP.
GOST 30333-2007 compliant CSP has to go via registration in the competent authority (CIS Center in Russia). This requirement will not be transferred into new version of GOST 30333-, since CSP will be reviewed by the authority during the registration phase for the chemical products according to the applicable registration deadline to be set by the EEC Decision (transitional periods will apply for the chemical product registration). The new version of GOST 30333- will likely foresee a procedure similar to the CSP registration, but on the voluntary basis. This will be a type of review of the CSP done by the authority before product registration as such is required. This will be useful for companies to verify that CSP is fully GOST 30333- compliant.
All chemical products in scope of Eurasia REACH will require CSPs according to GOST 30333- from the entry into force date of the Eurasia REACH. The requirement will be applicable to the EAEU manufacturer, Authorized Representative of the manufacturer and importer.
The regulation does not foresee any transitional period for the CSP requirement.
CSP will be required from the TR041 entry into force date. Now there is no official entry into force date set for the regulation, however the estimated implementation date of Eurasia REACH is 30th December 2023. Eurasian Economic Commission (“EEC”) will issue a new EEC Decision on TR041 implementation date, once 2nd tier legislation (implementing regulations) of Eurasia REACH, Order of Inventory Formation and Order of New Substance Notification, are approved.
An Authorised Representative (“AR”), if appointed, as Authorised Representative for the chemical product in question, will actually be fully responsible for the CSP content and adherence to GOST 30333-.
At the moment, the AR is able to submit CSP for the registration as required by GOST 30333-2007, if for some specific reason a manufacturer is required to make such CSP format already now even while GOST 30333-2007 is not mandatory. A client in Russia may require CSP compliant with GOST 30333-2007 from its foreign suppliers. In practice, it means that CSP has to be prepared according to GOST 30333-2007 and registered with the competent authority.
In the future, once new version of GOST 30333- is approved, an Authorised Representative will be able to submit CSP for the voluntary authority review according to the new version of GOST 30333-.
CSP will be required from the entry into force of the Eurasia REACH, therefore, it is important to start the preparation of the CSPs as soon as the new version of GOST 30333- is approved.
Through our office in Moscow we are able to provide a comprehensive CSP related services for Non- EAEU manufacturers and EAEU importers, where required.
Our CSP services include:
- Authorised Representative (AR) Service
- Chemical Safety Passports (“CSP”) Preparation according to GOST 30333-
- Chemical Product Classification Service according to GOST 32419-
- CSP Registration/Voluntary Review Service with Competent Authority according to GOST 30333-2007/30333-202X
- Grouping of chemical products into single CSP
- Review and compliance check of the CSP developed by the Client
- Eurasia REACH consulting services
- Eurasia REACH regulatory monitoring service