Via our office in Moscow, REACHLaw OOO, we are happy to help you as both your Nominated Representative and service provider to fulfil all the requirements of the EURASIA REACH regulation.
The Technical Regulation of Eurasian Economic Union (EAEU) on Safety of Chemical Products ТR.No.041/2017 approved on March 3rd 2017 (“Eurasia REACH”) requires companies (legal entities), manufacturing or importing substances and mixtures into the EAEU countries (Russia, Armenia, Belarus, Kazakhstan and Kyrgyzstan) at any tonnages to register these substances and/or mixtures at the Competent Authorities (to be appointed at a later stage) in the EAEU member-states.
Since Eurasia REACH is not in force yet and the 2nd tier legislation being in the draft phase, member-states will be compiling national inventories to list all the existing chemicals on the EAEU market. The inventory notification process in Russia has started as of 11th of November 2019. Furthermore, Eurasia REACH requires companies to have GOST No. 30333-2007 compliant Safety Data Sheets before the substances or mixtures are placed on the EAEU market.
Non-EAEU companies that export substances to the EAEU may instead of having their importers take care of the Eurasia REACH obligations individually, appoint a so called Nominated Representative (located in the EAEU) to take care of these Eurasia REACH importer obligations, meaning that each importer in the EAEU would be considered as downstream user only already covered by the compliance activities of the Nominated Representative. Alternatively, the EAEU importer(s) can also take care of the Eurasia REACH obligations individually.