Overview
On 1 July 2022, The European Commission has issued guidance on the interaction between the REACH Regulations and the recent EU sanctions imposed under Council Regulations 269/2014 and 833/2014, in particular the sanctions adopted following Russia's military aggression against Ukraine.
In summary, the key takeaways are:
- Data owners cannot engage in data sharing negotiations or other transactions with a person designated under Council Regulation 269/2014, or owned/controlled by a designated person under this regulation; ongoing negotiations should be suspended;
- Funds should not be transferred to a person designated under Council Regulation 269/2014, or owned/controlled by a designated person under this regulation; they can be held in an escrow account, and ECHA can be involved in case of disagreement;
- Companies or groups of companies who entered into agreements with companies before they were designated under Council Regulation 269/2014, or owned/controlled by a designated person under this regulation, must take the necessary actions, taking into account business operations and existing agreements;
- Lead registrants who are designated under Council Regulation 269/2014, or owned/controlled by a designated person under this regulation, should be changed;
- Lead registrants cannot submit information, including dossier updates, on behalf of persons designated under Council Regulation 269/2014, or owned/controlled by a designated person under this regulation;
- Only representatives cannot represent persons designated under Council Regulation 269/2014, or owned/controlled by a designated person under this regulation.
For a complete overview of sanctions adopted by the EU following Russia's military aggression against Ukraine please see here.
For further information see Frequently asked questions on REACH regulation concerning sanctions adopted following Russia’s military aggression against Ukraine (europa.eu).
