The nomination period for the Russian Inventory is formally closed now. During this nomination period, the GPC group has helped 20+ companies to nominate 350+ substances. The Russian inventory, which is expected to be published by the end of 2020, will be forwarded to the Eurasian Economic Commission to form a common Eurasian substance Register.
GPC Group summarizes three scenarios for companies that exporting to Russia:
- For the companies that have nominated to the Russian inventory, the next step will be the pre-registration and registration of substances in accordance with the TR 041. For now, no official information regarding per-registration and registration is available.
- For those companies that did not nominate to the Russian inventory but have been exporting chemicals to the Russian market before 2nd June 2021 (enforcement of TR 041), there is an “exceptional” procedure. A substance that is not present in the Russian Inventory will be considered as “new” for the Russian market. To place that substance laboratory expertise and extensive documentation is expected to be required. The “exceptional” procedure allows a simplified nomination procedure for substances that have not been nominated to the Russian Inventory, but for which a proof can be provided that they have been circulating on the Russian market before the TR 041 enforcement (2nd June 2021).
- The companies that have not nominated their substances to the Russian inventory and have not been exporting them to Russia before will be required to nominate their substance to the inventory in accordance with the TR 041. This implies that their substances will be considered “new” for the market and have to be nominated to the inventory before registration. To nominate “new” substances to the Inventory will require laboratory expertise and extensive documentation. All the details on documentation are expected to be announced at the beginning of the next year 2021.
GPC will continue to keep you updated on the news regarding the Russian inventory and TR 041.