Here is how we can help you submit the inventory:
1.If you do not have a representative in Russia – we can submit the inventory of your substances on your behalf.
2. If you have a representative in Russia – we can prepare and complete the inventory submission forms.
Update: the deadline for the inventory submission has been extended to 1 May 2020.
What is “chemical inventory”
Chemical inventory in Russia is one of the steps that are to be taken in preparation for the entry into force of Technical Regulation on the safety of chemical products (TR EAEU 041/2017). The first step is creation of the Russian national part of EAEU Chemical Register.
How is inventory performed
Inventory of chemical products is a voluntary procedure during which the company can submit information on chemicals it places on the EAEU market for their inclusion in the Register, thereby declaring them as “existing” in the customs territory of the Union. After the entry into force of the EAEU TR 041/2017 (the "Russia REACH" or "EAEU REACH"), all chemicals that are not listed in the register will be considered “new” for the customs territory of the Union and must be subject to a notification procedure — a comprehensive study of hazardous properties and risk analysis of human health — before they are put into circulation and the environment with a chemical safety report. It is understood that only really new, unexplored chemicals will be notified.
At the inventory stage, minimum information on chemicals is requested, the submission of information does not require payment of state duty (free of charge) and / or the submission of any documents confirming the fact of circulation of the substance on the territory of the Russian Federation. For those companies that for some reason did not participate in the inventory and after the entry into force of the EAEU TR 041/2017, found that their substances are not in the register (and therefore are identified as new chemicals), a deferred norm is provided: until June 2, 2023 for years, companies have the right to provide information on a chemical substance for inclusion in the register without a notification procedure, but subject to the provision of documents (information) confirming the circulation of a chemical substance on the Union market before the effective date TR EAEU 041/2017. Confirming documents may include a supply agreement (purchase and sale), a bill of lading, information on the presence of a chemical in the national register of chemical products of a Member State, etc.
After the entry into force of the EAEU TR 041/2017 and the termination of the deferred norm, all chemicals that are not in the register before being released to the Union market (including as part of mixed chemical products) must be notified (see clause 11 of the EAEU TR 041/2017).
Who is to perform the inventory
Manufacturers, importers and authorised representatives of the manufacturer (in case of foreign manufacturers).
Chemicals subject to chemical inventory
All chemicals that your company places on the EAEU market are subject to inventory: both when they are placed a separate product or as part of a mixture.
For chemical products put into circulation on the EAEU market as a chemical, in addition to the main component, it is necessary to take into account all impurities and additives present in a concentration of more than 0.1% (by weight).
For mixtures all the components should be considered that are present in concentration above 0.1% (by weight). If a substance is present in the composition of a mixture in a concentration of less than 0.1%, but it is likely that its content may subsequently be increased, it is recommended to also include this substance into the inventory.
Inventory is not required to be performed for the following chemicals and substances:
• those listed in Appendix No. 1 to the EAEU TR 041/2017 (a list of chemical products that are not subject to technical regulation). These include medicines and veterinary medicines, cosmetics and perfumery, chemicals that are sources of ionising radiation, subsurface resources that have not been chemically treated or altered (minerals, ores, gas, petroleum gas, oil, etc.), food and biologically active additives, etc.;
• those subject to a “vertical” technical regulation (for example, the technical regulation of the Customs Union “On requirements for lubricants, oils and special fluids” (TR TS 030/2012) or Technical Regulation “On the safety of cosmetic products”).
Important to note that raw materials for cosmetics and other products that are suplied on their own are not exempt from the notification (inventory submission).