The Russia Federation issued in final the Technical Regulation on the Safety of Chemical Products (TRSCP; Decree No. 1019) in October 2016 to establish a framework for regulation of chemical substances. Its implementation created a chemical inventory to include chemicals and mixtures in circulation and those intended for circulation in the territory of the Russian Federation. Inventory information is to be submitted online to the Russian Federations Governmental Industry Information Exchange Platform (GISP), which opened for submittal of substance information in November 2019. The initial submission deadline of January 1, 2020, has been extended to July 1, 2020.
Information requirements include:
Chemical identification information, including IUPAC name, synonyms, and molecular and structural formula;
Volume as a three-year average or planned deliveries;
Hazard classification according to Russian Gosudarstvennyy Standart (GOST) classification standards;
and Company data.
Some data elements are only required if available. Information must be submitted in the Russian language by an in-country legal entity; a company without a legal entity in Russia can appoint an Authorized Representative (AR) to submit information on its behalf and cover importation by its customers into Russia. The appointment of an Authorized Representative and timely submission allow a non-Russian company to maintain an uninterrupted supply chain into the region and support its Russian customers.
The TRSCP closely parallels the implementation dates in the Eurasian Economic Union (EAEU) Technical Regulation (TR) EAEU 041/2017, which was issued in final in 2017 and established a regional chemical management framework. Member countries of the EAEU include the Republic of Armenia, the Republic of Belarus, the Republic of Kazakhstan, the Republic of Kyrgyzstan, and the Russian Federation.
The implementation date for the EAEU chemicals framework is June 1, 2021, and includes the registration of mixtures as well as substances. Each member state is to develop an inventory of the chemicals in commerce in its country by January 1, 2021. These inventories are to be consolidated into a regional inventory by June 1, 2021. The regulation provides for late nominations to the inventory until June 1, 2023, for substances or mixtures on the market prior to June 1, 2021.
The Russian regulation is expected to be rescinded when the EAEU sub-regulations are implemented. Entities exporting products to the Russian market, until then, should nominate their substances and mixtures to the Russian chemical inventory to ensure continued access to the Russian market and to avoid the requirement to submit a new chemical registration after the inventory nomination process closes. Chemicals submitted to the Russian and other member state inventories will form the basis for the inventory of chemical substances and mixtures of the EAEU.
ACTA Group, 2 April 2020