Are you Compliant with Eurasia REACH?

Technical Regulation of Eurasian Economic Union (EAEU) on Safety of Chemical Products No 41 (TR EAEU 041/2017), was adopted on March 3, 2017 and will come into force on June 1, 2021. It applies to five Eurasian union countries (EAEU): Russia, Kazakhstan, Belarus, Armenia and Kyrgyzstan. After the TR EAEU 041/2017 takes effect, importers and manufacturers of chemical products must comply with the Technical Regulation on Safety of Chemical Products (TR EAEU 041/2017). The TR EAEU 041/2017 establishes mandatory requirements for any chemical substance(s), mixture, or other chemical products intended to be placed in the market in EAEU states (i.e. requirements for the safety of chemical products, conformity assessments, product identification and labelling, and terminology). Eurasia-REACH covers all types of chemical substance(s) except those listed in Annex I of the regulation. Eurasia-REACH will require companies to submit registrations of their chemical substance(s) to a member state authority within the EAEU. The type of registration will vary depending on whether the chemical is new or existing. Existing substances will receive an individual registration number and new substances will require an additional notification procedure. Foreign companies located outside of the EAEU intending to place their chemical substance(s) in the EAEU market may submit their existing chemical substances to the Inventory and register later via a ‘Nominated Representative’. With Eurasia REACH coming into effect in June 2021, it is unlikely that Russia’s separate version of REACH will be maintained along with it. With its implementation it is likely that Eurasia REACH will include several provisions to which chemical product companies, both domestic and foreign, will need to comply. Staying abreast of chemical regulatory information is important for chemical safety professionals of all types to establish a strong, efficient business plans. Suppliers and companies or individuals must take care to avoid common mistakes and ensure that they notify about the new chemicals and must submit a comprehensive study of their hazardous properties and a chemical safety report. This needs to be carried out before the chemicals are marketed in Russia. Talk to our REACH specialist to be compliant with Eurasian REACH regulation.

CMRT & CRT Update

New Version of Conflict Mineral Reporting Template CMRT v 6.01 and Cobalt Reporting Template CRT v 2.11 is released by RMI. CMRT v 6.01 (Conflict Mineral Reporting Template) RMI has released the new version of CMRT on 19th May 2020, which will replace the current version of CMRT v 5.12. The CMRT v 6.01 must be used for the next reporting year. For the current reporting year, all organization can use the CMRT v 5.1 or higher. The major changes that you will see in CMRT v 6.01 include: Corrections of all bugs and errors Updated ISO country, state and province lists Conformance to IPC-1755, which incorporated EU Conflict Minerals Regulation in the wordings of the following questions: Q 4 (newly added), Q H (formerly Q I), removal of former question C Updates to the Smelter Reference List and Standard Smelter List The next version of the CMRT is expected to be released during March-April 2021 CRT v 2.11 (Cobalt Reporting Template) RMI also updated the CRT (Cobalt Reporting Template) to CRT v 2.11 on 19th May 2020, which will replace the current CRT v 2.0 released on 30th October 2019. The Cobalt Reporting Template is a free, standardized reporting template developed by the Responsible Minerals Initiative to identify choke points and collect due diligence information in the cobalt supply chain. The template was formally launched on December 21, 2018. The major changes to the CRT v 2.11 are updates to the Smelter Reference List, which includes Cobalt Crude refiners that are designated Eligible in the Smelter Database. The next version of the CRT is expected to be released during September-October 2020 Talk to our global compliance expert to get help with your Conflict Minerals and Cobalt Compliance programs, that covers supplier training, CMRT / CRT collection and a robust supplier engagement platform or write us at [email protected]

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