[update Nov. 1st 2021] TR EAEU 041/2017, often referred to as the «Eurasia REACH», is the new Eurasian Economic Union Technical Regulation “on the Safety of Chemical Products” that was adopted by the decision of the Council of the Eurasian Economic Commission on March 3, 2017 and was expected to enter into force on June 2, 2021.

The official information letter of the Ministry of Industry and Trade of Russia confirmed that the initial effective date of the TR 041 - June 2, 2021 is not valid. The new date of entry into force of the TR 041 will be determined by the Eurasian Economic Commission together with the governments of the EAEU member states, taking into account the results of the coordination of 2nd level documents to the technical regulation. Enforcement date of the TR 041 will be 2 years after the adoption of the 2nd level documents. The most optimistic forecast is the end of 2023 (in case the 2nd level documents are adopted in Q4 of 2021).

The main requirements are : 

1. Inventory process (to form the Register of chemical substances existing on the EAEU market) - it is a non-mandatory, but recommended requirement. It was ongoing until 1-st August 2020 in Russia (is expected to be open again once the enforcement date is known), currently ongoing in Belarus, Kazakhstan and Kyrgyzstan;

2. Safety Data Sheet compliant with GOST 30333 standard - mandatory and required once TR 041 enters into force; 

3. New Substance Notification - this requirement is mandatory for new chemicals, and required once TR 041 enters into force and before chemical product containing new substance is placed on the EAEU market; 

4. Registration of chemical products - a mandatory requirement, implementation depends on whether the product is a substance or a mixture and according to the applicable tonnage band. 

All chemical substances as such, or as part of a mixture, which are placed on the EAEU market are in scope of TR 041.

Concerning point 2 Safety Data Sheet: after the effective date of TR 041, a Safety Data Sheet will be a mandatory document to be submitted within the registration (as part of documentation package to prove conformity to the TR 041).

• This will be required for all chemical products (not only hazardous).
• A manufacturer, an importer or an authorized representative of the manufacturer can compile a Safety Data Sheet.
• GOST 30333 2007 is a valid standard applied when developing a chemical safety passport valid in Russia (and the EAEU) from 2009. It is currently being revised to meet the requirements of the EAEU TR 041/2017 and in order to meet GHS rev.7. The revised document is planned to be adopted in 2022. 

Concerning point 4 Registration: the following registration time periods are expected:

• chemical products that are chemical substances put into circulation in the amount of > 1000 t/y : after the effective date,  100-1000 t: 2 years after enforcement date, 1-100 t: 4 years after enforcement date; <1t a separate decision of the EAEU Commission will be taken;
• for chemical products that are chemical mixtures in the amount of >1000 t: 5 years after enforcement date; 100-1000 t : 7 years after enforcement date; 1-100 t: 9 years after enforcement date;  <1t a separate decision of the EAEU Commission will be taken.

----------------------------------

Link to GDrive : EURASIA EAEU Chemical Regulation (substances notified, latest webinars, draft letter for customers,...)

Contact : patricia.villers@syensqo.com