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The Impact of the EU’s Russia Sanctions on the Obligations under EU Chemicals Legislation

Eva Monard, Hannah Widemann, Elli Zachari

DOI https://doi.org/10.21552/stoffr/2022/4/3



The EU’s sanctions adopted in the wake of the Russian invasion of Ukraine are in numerous ways unprecedented, especially considering the close economic ties that previously existed between the EU and Russia. The sanctions packages have therefore largely separated the two economies (as they intended to do) and thereby severely affected businesses and supply chains in and outside of Europe. While most multinationals are well aware of the impact on trade and have set up advanced compliance systems to ensure no prohibited trade in goods and provision of services takes place, there appears to be less awareness of the impact of the EU’s sanctions on operators’ compliance with EU chemical legislation. However, the sanctions also impact the obligations under the EU’s chemicals regulations, most notably on mandatory sharing of (vertebrate) animal studies but also related to the joint submission of registrations. This contribution hence examines the interplay between the respective obligations under the EU’s sanctions regime and the EU’s chemicals regulations, to allow operators to asses and determine their compliance strategies. While the contribution focuses on the interaction with the Russia sanctions, the same comments would apply generally to other sanctions imposed by the EU.

Eva Monard, Member of the Brussels Bar, is a partner at Steptoe & Johnson LLP and advises clients on EU and international trade issues, including EU sanctions and trade controls. For correspondence: emonard@steptoe.com. Hannah Widemann, LL.M. and Member of the Brussels Bar, is a senior associate at Steptoe & Johnson LLP and advises clients on EU regulatory compliance questions in the areas of chemical and product regulations, including biocides, REACH, CLP and plant protection products. For correspondence: hwidemann@steptoe.com. Elli Zachari, LL.M., is an associate at Steptoe & Johnson LLP and advises clients on EU and international trade issues, including EU sanctions and trade controls. For correspondence: ezachari@steptoe.com.The views and comments presented in this contribution reflect those of the authors and do not necessarily reflect the views or positions of any entities they represent. This contribution should not be construed as legal advice on any specific facts or circumstances. It was last edited on 12 December 2022 and does not reflect any developments thereafter.

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