StoffR - Zeitschrift für Stoffrecht

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Eva Monard, Hannah Widemann, Elli Zachari

Zeitschrift für Stoffrecht, Volume 19 (2022), Issue 4, Page 219 - 228

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.

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