Regulatory Affairs

Thanks to the efforts of the European Business Association (hereinafter – EBA), the Ministry of Economic Development and Trade of Ukraine (hereinafter – Mineconomy) promulgated the Draft Resolution of the Cabinet of Ministers of Ukraine on Amendments to the Technical Regulation on Detergents (hereinafter – Draft Resolution and Technical Regulation respectively)on 29 August 2014, which takes into consideration the position of business regarding the mandatory application of certain provisions of the Technical Regulation.

Preconditions: in our appeals and during meetings with the Mineconomy, the Association underlined the need to postpone the terms of compliance with the DSTU GOST 31340:2009 “Precautionary labelling of chemical products. General requirements” during the mandatory labelling of detergents. This was based on the fact that the new version of the Technical Regulation (adopted by the Resolution of the Cabinet of Ministers of Ukraine No.408 of 12 June 2013) set forth only a six-month transition period, which is a relatively short term for the transition of business to the new labelling (taking into account the complexity and duration of such a process) and for the retirement of products for relabeling, namely detergents, produced with precautionary labels under the Directive 67/548/EEC of 27 June 1967 (DSD) and the Directive 1999/45/EC of 31 May 1999 (DPD).

It should be also noted that the transition from the labelling system, according to the DSD and DPD, to the labelling system according to the CLP Regulation still continues in European countries, wherefore a few transition years were established by Regulation No.1272/2008 of the European Parliament and of the Council of 16 December 2008. Thus, the Introduction to the CLP Regulation for Professional Suppliers/Users sets forth that products (mixtures) shall be labelled from 1 June 2015 with the new signs, and the mixtures, produced under the preceding labelling system prior to this date and put into circulation, can be sold until 1 June 2017.

Another issue to be settled was to postpone the terms of executing control over the testing of the ability to decompose surfactants, contained in detergents, until 1 January 2018, which was determined by the lack of a legislative act establishing the methods of testing the ability to decompose surfactants contained in detergents, and enabling the conducting of respective tests. Moreover, the List of national standards for determining methods of proving the compliance of detergents with the Technical Regulation on Detergents has no reference to such a document.

The Mineconomy took into account the proposals of the Association regarding the Draft Resolution and postponed the term of mandatory compliance with the requirements of DSTU GOST 31340:2009 for the indication of security measures and special warnings in the marking of detergents until 21 June 2017; and the term of application of and compliance with the requirements for the ability to decompose surfactants contained in detergents until 2018.

Thus, the Association welcomes the promulgated changes and appreciates the assistance of the Mineconomy in this matter, and wish to express our gratitude to all EBA member-companies, which were actively involved in the amendment process, and we hope that the Draft Resolution will be brought to consent and adopted soon!