New Practices in REACH Compliance Supply Chains Amid EU Sanctions
Delve into the impact of EU sanctions on chemical trade with Russia and Belarus, offering insights on supply chain adjustments and regulatory compliance to navigate the evolving landscape effectively. Learn about the challenges faced by non-Russian customers and explore the implications of limited supply, increased costs, supply chain disruptions, and market volatility. Gain an overview of the EU regulations defining sanction restrictions and clarifications from the European Commission to stay informed and proactive in your trading practices.
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Presentation Transcript
New trading practises in REACH compliance supply chains in the light of EU sanctions against Russia and Belarus BELGRADE CHEMICALS MANAGEMENT CONFERENCE 30 May 2023
Why me? Name: Inessa Kiristaeva Position in REGARTIS : Customer Happiness Manager Background: Since 2008, I have been actively involved in supporting Russian industry in exporting chemical products to the European Union (EU). Experience: More than 30 Russian and Belarus chemical producers are customers of REAGRTIS for the EU and UK REACH compliance support.
Purpose of this presentation Unveiling the EU sanctions' impact on the chemical industry and sharing secrets for supply chains to rock and roll in this ever-changing landscape.
Impact of sanctions on non-Russian customers in the EU and other countries Limited supply: Sanctions restrict access to chemical products from Russian exporters, potentially leading to shortages or delays. Increased costs: Seeking alternative suppliers can result in higher procurement expenses due to transportation costs and scarcity of certain products.
Impact of sanctions on non-Russian customers in the EU and other countries Supply chain disruptions: Existing supply chains relying on Russian exporters may need adjustments or alternative sourcing options. Regulatory compliance: Non-Russian customers must ensure compliance with sanctions to avoid legal and reputational risks. Market volatility: Sanctions introduce uncertainty, affecting pricing and market stability for chemical products.
Overview of EU Sanctions against Russia and Belarus EU Regulations Defining Sanction Restrictions: Council Regulation (EU) No 833/2014 dated July 31, 2014 17 amendments Council Regulation (EU) 2022/1904 of 6 October 2022 Link to the consolidated text: https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX%3A02014R0833- 20221007&qid=1668439053545
Overview of EU Sanctions against Russia and Belarus Clarifications from the European Commission FAQ last update May 10, 2023: Guidance for national authorities and EU operators on the implementation and interpretation of sanction restrictions (Section G10. Chemicals). Link to the FAQ document: https://finance.ec.europa.eu/system/files/2023- 05/faqs-sanctions-russia-consolidated_en.pdf
Q&A Q: How do EU sanctions interplay with Regulation (EC) No 1907/2006 and other EU legislation on chemicals in general? A ( simple) : European Union sanctions take priority and apply over the general legislation when there is a conflict. While both should be interpreted to achieve their goals, the sanctions regulations hold greater weight and must be followed unless there is an exception applies.
EU Sanctions: Chemical Products in Focus The restrictive measures of Council Regulation (EU) No 833/2014 apply to: Individuals and legal entities under sanctions restrictions: Annexes IV, V, VI, XII, XIII, XIX Types of goods, products and technologies restricted for export from and import to Russia: Annex VII Category VIII Miscellaneous items, Category IX Special Materials and Related Equipment ( chemicals by CAS numbers) Annex XVII List of steel and iron products ( by CN codes) Annex XX list of jet fuels and fuel additives ( by CN code) Annex XXI, XXII, XXIII, XXIV, XXV list of different goods ( by CN code) Types of services: Article 5n (1)b
Sanctions & Exemptions for the type of products S: Article 3ea (1)(1a) prohibit access to ports to locks in the territory of the Union, to any vessel registered under the flag of Russia ... E: Article 3ea(5) By way of derogation from paragraphs 1 and 1a, the competent authorities may authorise a vessel to access a port or lock, under such conditions as they deem appropriate, after having determined that the access is necessary for: .. (b) the purchase, import or transport of pharmaceutical, medical, agricultural and food products, including wheat and fertilisers whose import, purchase and transport is allowed under this Regulation
Sanctions & Exemptions for the type of services S: The services of the EU Only Representative on behalf of legal entities, organizations, or bodies established in Russia within Article 8 REACH is considered business consulting and, accordingly, may fall within the scope of prohibited services under Article 5n(1) of Council Regulation 833/2014. E: Under Article 5n (7) of Council Regulation 833/2014 paragraphs 1 and 2 shall not apply to the provision of services intended for the exclusive use of legal persons, entities or bodies established in Russia that are owned by, or solely or jointly controlled by, a legal person, entity or body which is incorporated or constituted under the law of a Member State, a country member of the European Economic Area, Switzerland or a partner country as listed in Annex VIII.
Sanctioned Chemical Chains: From Restriction to Innovation Change the company ownership / role of manufacture; Strategic Adaptation: Modifying Chemical Composition for CN Code Compliance or nonrestricted concentrations.
Sanctioned Chemical Chains: From Restriction to Innovation Search for new compliance supply chains in the EU.
Sanctioned Chemical Chains: From Restriction to Innovation Exploring New Markets Beyond the EU for Chemical Supply: Turkey, South Korea, Serbia, Kazakhstan, and more
Key Takeaways Comprehensive Understanding of Sanction Regulations often requires legal expertise; Enforcement of Sanction Regulations varies among EU countries, leading to potential differences in interpretations; EU Compliance for Chemical Products may become your responsibility; Financial Operations can be impacted by EU sanctions.
THANK YOU for your attention! Chart your compliance course through the regulatory seas with REGARTIS. experts@regartis inessa@regartis.com.... name @regartis.com www.linkedin.com/company/regartis/
