Compliance Alert: EAEU RoHS Draft Proposed Amendment
EAEU: Draft Decision for approving Technical Regulations on Restriction of Hazardous Substances in Electrical and Electronic Equipment, Decision No. 113, 2016. The Proposed Amendment is about addition of restricted chemicals, marking and requirements for e-waste, revised scope, etc. EAEU members include Armenia, Belarus, Kazakhstan, Kyrgyzstan, and Russia. Electric and electronic equipment sold in the EAEU must comply with the EAEU Technical Regulation on the Restriction of the Use of Hazardous Substances in Electrical and Radio-Electronic Products. In the EAEU technical regulation, six RoHS substances are prohibited, such as: Lead Cadmium Mercury Hexavalent chromium Polybrominated biphenyls and Polybrominated diphenyl ethers This draft has been amended to include: New added substances. The following substances are proposed to be included in Annex 2 of Technical Regulation No.113: Diethylhexyl phthalate Butyl benzyl phthalate Dibutyl phthalate Diisobutyl phthalate New requirements by EAEU RoHS on responsibility and disposal The draft proposed to feature new requirements on disposal of electric and electronic equipment and also on the responsibility of extended producers. Concerning the requirements of the restriction of use of hazardous substances: processes of disposal of electrical and electronic equipment, a new requirement to Section IV shall be administrated in conformity with the necessities of the national legislation of the Member States of the Union, like the necessities defined in proposed Annex 4. Changes are proposed in Marking requirements and following documentation requirements should even be supplemented as: a separate waste collection marking, as provided in proposed Annex 5, should be affixed thereto product, and mentioned in its accompanying documentation. Accompanying documentation should have the extra following information: Indication for not disposing e-waste along with unsorted solid household waste. Electronic waste should be collected separately from other waste Hazardous substance information and its possible harmful effects on human health and the environment should be mentioned in the products, if it contains hazardous substances There should be a separate waste collection marking There should be an information “Hand over for recycling if not using. This will prevent damage to the environment” Scope expansion: The draft proposes to a brand new “open scope” category of products. This adds a brand-new entry 13 to the lists of products in Annex 1, which include: “Other electrical and electronic products not specifically mentioned in Article 3. Electrical and electronic components listed in items 1-12 of Annex 1”. The deadline for comments is 20 January 2022.
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.