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On 17 February 2021 the Eurasian Economic Commission (EEC) released a draft of the implementation documents of the Eurasian Economic Union (EAEU) Technical Regulation (TR) On Safety of Chemical Products (041/2017) (also known as Eurasian REACH) for a second public discussion. The second-tier implementation documents are an important part of the regulation of the chemicals in the EAEU.
Verisk 3E Review
The Eurasian REACH is the main regulation of chemical products in the EAEU territory (Russia, Belarus, Kazakhstan, Armenia, and Kyrgyzstan). The act introduced the registration of chemicals, a notification process and set Safety Data Sheet (SDS) and labeling rules. The rules align with the seventh revised edition of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Originally, the Eurasian REACH was set to be enforced on 2 June 2021. The newest date proposed by the EEC is 30 November 2022.
The enforcement of the Eurasian REACH is conditional on the timely adoption of the second-tier implementation documents. The original deadline for the adoption and enforcement of these documents was 1 December 2018. According to the most recent information, the second public discussion of the documents should end on 1 April 2021 and we can expect the adoption of these documents in the second half of 2021.
The second-tier implementation documents contain significant corrections in Annex 7 that list carcinogens, mutagens, and dangerous for reproductive function chemicals class 1 and 2. According to the Commonwealth of Independent States (CIS) center, due to the extensive changes during the two years of development, the classification of chemicals supporting Annex 7 remains the only inconsistent element of the whole package of second-tier documents. These inconsistencies required the whole package of implementation documents to undergo the process of public discussion for a second time.
The Eurasia REACH is a conceptual document that needs the second-tier implementation documents to detail the processes of registration, notification, etc., of chemicals. The second-tier implementation documents will govern these processes:
- Registration of chemical substances and mixtures of the EAEU
- Formation and maintenance of the affiliated EAEU registers of chemicals and mixtures
- Notification of new chemicals
In addition, the documents include the following in the Annexes:
- List of chemicals that have carcinogenic or mutagenic effects, affect reproductive function or have chronic toxicity to the aquatic environment (Annex 7)
- Template of an application for the notification (Annex 1)
- Guidance on the preparation of a chemical safety report (Annex 2)
Verisk 3E Analysis
All stakeholders should be aware of the content of the second-tier implementation documents because they contain rules on the registration of chemicals, classification of chemicals, and notification process, including all relevant templates. When the Eurasian REACH is enforced, all rules will become mandatory. Successful compliance is based on early and thorough preparation.
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