REGULATORY UPDATES

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Recently in a personal communication with CIS Centre, Russia we got notified that due to the COVID-19 crisis the Russian Inventory Notification Deadline due on 1st May 2020 has been extended 3 more months till 1st August 2020.

 

Below is the full excerpt of the communication:

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On the extension of the deadlines for the submission of information as part of an inventory of chemicals in connection with the spread of COVID-19.

 

In connection with the transfer of a number of enterprises to remote operation due to the threat of the spread of a new coronavirus infection and in order to provide industry support measures, the Ministry of Industry and Trade of the Russian Federation informs in addition to the letter dated February 17, 2020 No. IM-10702/13 about the extension of the deadlines for submitting information procedures for the inventory of chemicals (including as part of mixtures) in circulation and planned for circulation in the territory of the Russian Federation, until August 1, 2020

 

With detailed information on the chemical inventory procedure, please familiarize at methodological recommendations http://minpromtorg.gov.ru/common/upload/files/docs/Pismo_EVL_s_metod.rek-mi.pdf ) and on the website of the Association “NP KIC CIS” in the section “Preparation for inventory” (URL: https://ciscenter.org/tabstest/faq.php )

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If you are exporting to Eurasian Economic Union (EAEU: Russia, Belarus, Kazakhstan, Kyrgyzstan, & Armenia) and has not yet notified your chemical(s) in the Russian Inventory then SSS within its Russian Legal entity can act as a Nominated Representative (located in the EAEU) for your company, and can free of charge submit your chemical(s) notification.

 

Please submit your CAS details here and for any specific queries reach out to our Regulatory Expert, Ketki Kulkarni at [email protected].

 

What happens if you miss this inventory notification deadline?

If your substance is not present in the inventory (notified by someone else) then it will be considered as new and will be subject to the submission of a comprehensive study of the properties with a chemical safety report.

 

You can find the FAQ’s on Eurasia REACH (TR 041) here.

In a private communication, Health and Safety Executive (HSE, UK-Government), has communicated to SSS that the UK-Government can request an extension to transition period due to end at midnight on 31 December 2020, provided it is done before 1 July 2020.

 

Further, the UK-REACH/CLP helpdesk is not currently aware that the UK-Government has indicated that it intends to request an extension to the transition period.

 

During the transition period, the UK remains within the EU-REACH regulatory framework. UK-REACH and the UK-REACH IT system ‘Comply with UK-REACH’ are not in operation. Guidance on how to register under UK-REACH is being prepared. Details of the supporting services available to potential registrants (including account creation) for UK-REACH will be released in due course.

 

SSS is in constant touch with relevant UK-REACH bodies and will keep you updated as an when the situation would change and/or there are any new advancements.

 

If you have any further questions then you can contact our UK-REACH manager Priyanka Manapure at [email protected].

 

You can also find our UK-REACH FAQs here.

Taiwan’s Environmental Protection Administration (EPA) has amended its chemical control law Toxic Chemical Substances Control Act (TCSCA)’ and renamed it to Toxic Chemicals and Concerned Substances Control Act (TCCSCA). This regulation has come into force from January 1, 2020. 

 

Companies that manufacture or import Existing Chemical Substance in an annual amount of 100 kilograms or more need to apply for Phase One Registration within 6 months from the date of exporting. Furthermore, if the chemical in a quantity that is above 1 tonne per year or more and falls under the list of 106 Priority Existing Chemicals (PECs) then companies need to do a Standard Registration. 

 

In the case of Confidential Business Information (CBI), exporters to Taiwan should communicate with their buyers and register via a Third Party Representative (TPR). 

 

As a TPRSSS can communicate in the supply chain on behalf of your company and also assist you with Phase One & Standard Registration. 

 
Please submit your CAS details here and If you have any further questions on TCCSCA compliance, please contact our Regulatory Manager Chia-Sui Hsu at [email protected]

 

You can also find our Taiwan’s TCCSCA FAQs here.

Turkey’s REACH regulation “KKDIK” came into force in June 23rd, 2017 replacing three existing regulations: “Bylaw on Inventory and Control of Chemicals”, “Bylaw on Restriction and Ban of Hazardous Substances & Mixtures” and “Bylaw on Safety Data Sheets of Hazardous Substances & Mixtures”. Being mostly similar to EU REACH, Turkey REACH has its own differences in registration requirements and deadlines.

 

The closest approaching deadline for Turkey REACH is the deadline for pre-registration (pre-SIEF notification) of the substances and  from 1st Jan 2021 only those companies who have “Pre-Registered” their substances (under transitional article 1 of KKDIK (Turkey Reach) and article 4.2 of the official guide on registration) would be allowed to place substances in Turkey.

 

If you have not yet pre-registered, you can do so until 31st Dec 2020.

 

To pre-register you may need to appoint a Turkish Legal Entity as an Only Representative (like EU Reach) that would act on your behalf to comply with KKDIK.

 

Certain substances may be exempted, and certain may require additional attention such as requirements of SDS, etc.

 

To assess the specific applicability of the regulation to your substances, please share your CAS details here, and as a free service to our existing & future clients, we would provide a detailed response of the regulatory applicability, and a way forward for compliance with KKDIK. After receiving the response, you may decide if you want us to follow up your compliance obligations under Turkey REACH.

 

For any specific queries and service quotations please reach out to our Regulatory Experts at [email protected].

 

You can also find our Turkey's REACH regulation FAQs here.

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