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” or “TR041”) implements mandatory compliance procedures required for chemical products placed on the EAEU. The official entry into force of the regulation is 2nd of June 2021, however due to several delays during the implementation phase, the commencement date is likely to be shifted to 30th December 2023. The Regulation cannot enter into force without approval and commencement of the 2nd tier (implementing regulations) and GOST Standards introduced in the TR041. These are supposed to be finalized during 2021
Manufacturers, importers, and authorised representatives of the EAEU (Russia, Armenia, Belarus, Kazakhstan and Kyrgyzstan) of non-EAEU manufacturers must comply with the requirements of Eurasia REACH. According to Eurasia REACH, all chemical products placed in the EAEU must comply with GOST 30333 – Chemical Safety Passport and chemical product registration requirement according to the applicable tonnage-based and product type registration window.
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 covered by the compliance activities of the Authorised Representative. Alternatively, the EAEU importer(s) can also take care of the Eurasia REACH obligations individually.
Via our office in Moscow, REACHLaw OOO, we are happy to help you as both your Authorised Representative and service provider to fulfil all the requirements of the EURASIA REACH regulation.
Our Office in Russia
REACHLaw OOO address: 119180 Moscow, 3rd Golutvinskiy Per. Build. 6 11, office 3, 5th floor. Russia
Contact Person: Olesia Pochapska, Senior Manager at REACLaw Ltd. Email: firstname.lastname@example.org
Our Support Includes
Authorised Representative Service
Manufacturing companies located outside of the Eurasian Economic Union ( “EAEU”), but placing their chemical products on the EAEU market can appoint a so-called Authorised Representative, registered as a legal entity or entrepreneur according to the requirements of the member-states, for the purposes of compliance with the requirements of Eurasia REACH. This means that each importer in the EAEU would be covered by the compliance activities of the Authorised Representative. Alternatively, the EAEU importer(s) can also take care of the Eurasia REACH obligations individually.
Authorised Representation is a special mechanism as allowed by the Regulation for maintaining Regulatory compliances for chemical substances on behalf of non-EAEU manufacturers that do not have or do not wish to have actual legal entity level presence within the EAEU.
Note that the Authorised Representative is responsible for the chemical products placed in the EAEU, including liability for Chemical Safety Passport compliance.
REACHLaw can provide you with the following Eurasia REACH compliance services:
- Authorised Representative One-Time Setup Service
- Regulatory Monitoring Service by the Nominated Representative
- Inventory Notification Service
- Chemical Safety Passports
- Competent Authority SDS Review Coordination Service
- Communication with authorities / regulatory assignments
Via our office in Moscow we are happy to provide you with Authorised representative services.
Regulatory Monitoring Service
REACHLaw supports companies in providing general Eurasia REACH consulting (answering general Eurasia REACH queries) to the client by answering questions via email/phone on the annual basis. Furthermore, an annual report covering the main regulatory updates under TR041 will be sent to the client in the beginning of each calendar year.
The service includes:
- Answering Client’s general queries on Eurasia REACH
- Annual reporting to the Client (Eurasia REACH updates)
- Informing Client (upon request) about new developments of the Regulation
Note: Specific requests, including product-specific requests and queries under other Technical Regulations in the EAEU will be charged according to Consulting Service fees as separately agreed with the Client.
Eurasia REACH Scoping Service
REACHLaw provides resources and the expertise necessary to perform a Regulatory Scoping Service of the Client’s chemical product portfolio on the EAEU/Russian with regards to the applicability of the TR041 and GOST 30333 requirements.
REACHLaw experts will provide a detailed assessment of the regulatory compliance procedures under TR041 and the timeline in relation to the Client’s chemical products placed on the EAEU/Russian market.
For more information on this services please contact us at email@example.com
Chemical Safety Passports Preparation - GOST 30333
Eurasia REACH requires all chemical products placed on the EAEU market to have Chemical Safety Passports (“CSP”) according to GOST 30333 once it enters into force. At the same time, current valid GOST 30333-2007 requires CSP to be registered at the competent authority, while the updated version currently under revision does not have such obligation. Therefore, depending on the applicable requirements at the time of the CSP preparation request the requirement for the CSP might vary.
REACHLaw will prepare a Chemical Safety Passport (“CSP”) compliant with GOST No. 30333 standard and all other applicable standards valid at the time of the Client request. The Client shall provide an English language version of the latest EU REACH compliant SDS (or in another format as agreed with REACHLaw separately), composition information and other relevant information in the requested format. The Russian translation of the EU SDS must be provided if available. If a Russian SDS version is not available, REACHLaw will make the translation at additional cost.
GOST 30333-2007 is a valid CSP standard in the EAEU that requires CSP registration with the competent authority CIS Centre. The authority is manually checking each Section of the CSP to verify that all requirements of GOST 30333-2007 and related applicable GOST standards, hygiene standards (GN), national requirements are met. The authority is also checking classification and labelling of the chemical product verifying the composition of the product up to 0,1% w/w.
Some of the requirements to be met are listed in the following standards:
- 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 32421-2013 “Classification of chemical products, the danger of which is due to physico-chemical properties. Test methods for explosive chemical products.’’
- GOST 32423-2013 “Classification of mixtures (health hazards)”
- GOST 32424-2013 “Classification of chemicals for environmental hazards. General principles”
- GOST 32425-2013 “Classification of mixtures (environmental hazards)”
- GOST 12.1.007-76 “Occupational safety standards system (SSBT). Harmful substances. Classification and general safety requirements”
- GOST 19433 “Dangerous goods. Classification and labelling”
- GOST 12.1.004-91 “Occupational safety standards system. Fire safety. General requirements.”
- GOST 12.1.044-89 “Fire and explosion hazard of substances and materials.”
- Nomenclature of indicators and methods for their determination.”
- GOST 17527-2003 “Packaging. Terms and Definitions.”
- GOST 20231-83 “Cargo containers. Terms and Definitions.”
- GOST 21391-84 “Means of packaging. Terms and Definitions.”
- GOST 9980.4-2002 “Paintwork materials.”
- GOST 30852.0-2002 (IEC 60079-0: 1998) “Explosion-proof electrical equipment.”
At the moment, compliance with GOST 30333-2007 is voluntary, but often can be a condition stipulated by the Client in Russia/EAEU.
Once Eurasia REACH enters into force, CSP compliant with GOST 30333- will become mandatory. The requirements for CSPs are stipulated in Eurasia REACH (Art.36-43). The CSP must be available once the chemical products are placed on the EAEU market. Therefore, the CSP must be prepared before the product is placed on the EAEU market for the first time.
Chemical Safety Passport Registration Service
REACHLaw will coordinate the registration of the Chemical Safety Passport (“CSP”) with the Competent Authority. The service includes communication with the authority and providing additional information and/or corrections to the CSP, payment of the authority fee and reporting to the Client.
The service cost consists of the Competent Authority fee and REACHLaw fee.
Communication with Authorities/Regulatory Assignments
General / Eurasia REACH / SDS related / other EAEU technical regulations official communication services with relevant authorities in the EAEU.
This service can be requested by the Client as an additional assignment or may be a result of an official authority request addressed to REACHLaw as Client’s Authorised Representative. In the latter case, REACHLaw will inform the Client and agree on the next steps and potential scope of the assignment.
Chemical Product Classification Service
REACHLaw will provide a Classification service for the Client’s chemical products (substances or mixtures) according to the applicable classification standards in Russia and the EAEU valid at the time of the assignment. GOST 32419–2013 “Classification of chemical products. General requirements” provides guidance and references to other more specific standards to be applied when classifying a chemical product in the EAEU (see CSP Service above for the list of potentially applicable GOST standards).
The Client will be requested to provide compositional information up to 0,1%, EU REACH SDS or similar document and other information deemed necessary for the specific classification project.