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Regulatory Affairs

27/ 11/ 2012
  Due to EBA’s lobbying efforts and practical experience of the working group established under the auspices of the Ministry of Economic Development and Trade of Ukraine on 21 November 2012 the new Draft Technical Regulation on  Detergents was published. New draft regulation takes into account the majority of the proposals provided by the European Business Association. Background: During the years 2008 – 2011 the Ministry of Industrial Policy of Ukraine had to implement the necessary measures to ensure that enterprises are prepared to fulfill the requirements of the Technical Regulation on Detergents, which unfortunately were not met in full. In particular, all necessary national standards on the  identification of detergent’s testing methods according to the Regulation (EC) No 648/2004 of the European Parliament and of the Council on Detergents  (hereinafter – Regulation EC) of 31 March 2004 were not developed and current national standards do not include all safety requirements of the Technical Regulation. As a consequence, the bodies on evaluation of conformity and testing laboratories were not able to fulfill all necessary tests of detergents to declare their conformity to Technical Regulation’s requirements. Thus, although the introduction of the Technical Regulation provided the opportunity for its voluntary implementation during three years, de-facto it was impossible. Moreover, unclear and ambiguous provisions of the Technical Regulation provide space for different interpretations (for example, concerning prohibition of images of fruits and other food on product’s labels) were huge obstacles for its implementation. It is worth noting that the first necessary amendments were introduced only on 6 June 2012. The Association submitted the list of appeals to the top government officials with the proposals to improve the provisions of the Technical Regulation for its full harmonisation with Regulation EC requirements. Moreover, due to the EBA efforts under auspices of the Ministry of Economic Development and Trade the working group was established, which included representatives of the State Inspection of Ukraine on Technical Regulation and Consumer Policy and conformity assessment bodies. As a result, on 21 November 2012 the new version of the Draft Technical Regulations on Detergents was published on the official web-page of the Ministry of Economic Development and Trade. New document considered the majority of the amendments and additions proposed by the EBA. We express our sincere gratitude to member-companies that were directly involved into improvement of the text of the Technical Regulation, as well as to state authorities for such effective and constructive cooperation. The Association will continue advocating the interests of its members to assure that the final edition of the Technical Regulation on Detergents complies with the European legislation as well as companies’ experience.

Due to EBA’s lobbying efforts and practical experience of the working group established under the auspices of the Ministry of Economic Development and Trade of Ukraine on 21 November 2012 the new Draft Technical Regulation on  Detergents was published. New draft regulation takes into account the majority of the proposals provided by the European Business Association.

Background: During the years 2008 – 2011 the Ministry of Industrial Policy of Ukraine had to implement the necessary measures to ensure that enterprises are prepared to fulfill the requirements of the Technical Regulation on Detergents, which unfortunately were not met in full. In particular, all necessary national standards on the  identification of detergent’s testing methods according to the Regulation (EC) No 648/2004 of the European Parliament and of the Council on Detergents  (hereinafter – Regulation EC) of 31 March 2004 were not developed and current national standards do not include all safety requirements of the Technical Regulation. As a consequence, the bodies on evaluation of conformity and testing laboratories were not able to fulfill all necessary tests of detergents to declare their conformity to Technical Regulation’s requirements.

Thus, although the introduction of the Technical Regulation provided the opportunity for its voluntary implementation during three years, de-facto it was impossible. Moreover, unclear and ambiguous provisions of the Technical Regulation provide space for different interpretations (for example, concerning prohibition of images of fruits and other food on product’s labels) were huge obstacles for its implementation. It is worth noting that the first necessary amendments were introduced only on 6 June 2012.

The Association submitted the list of appeals to the top government officials with the proposals to improve the provisions of the Technical Regulation for its full harmonisation with Regulation EC requirements. Moreover, due to the EBA efforts under auspices of the Ministry of Economic Development and Trade the working group was established, which included representatives of the State Inspection of Ukraine on Technical Regulation and Consumer Policy and conformity assessment bodies. As a result, on 21 November 2012 the new version of the Draft Technical Regulations on Detergents was published on the official web-page of the Ministry of Economic Development and Trade. New document considered the majority of the amendments and additions proposed by the EBA.

We express our sincere gratitude to member-companies that were directly involved into improvement of the text of the Technical Regulation, as well as to state authorities for such effective and constructive cooperation.

The Association will continue advocating the interests of its members to assure that the final edition of the Technical Regulation on Detergents complies with the European legislation as well as companies’ experience.

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