I was recently reminiscing with my husband about a trip we took last year with our good friends to Scotland and Ireland. It was a wonderful trip, and we were so lucky to get it in before this COVID pandemic has essentially halted all international travel. Even though travel is on hold, products can still be shipped through international channels. I wonder if everyone shipping internationally understands all of the global regulations that are applicable.
Are you shipping product outside of the US?
If your product is a chemical or a mixture, be certain that you are in compliance with the Chemical Inventory or Chemical Registration obligations for the destination country. If the country has a Chemical Inventory, all ingredients you are importing must be on the inventory list. If the country has a Chemical Registration requirement, you will likely want to work with a legal entity within that country to have your substances registered. These are often volume-dependent, so you need a good understanding of current and projected volumes. Also, be sure to understand the hazard communication laws that dictate the necessary elements of your Safety Data Sheet and product labels. You should understand if your product is subject to any Banned or Restricted lists. A Banned list means import into the country is prohibited. A Restricted list might allow importation if the substance is below a specified limit. It may also require a specific registration or permit to import.
Even if your product is an article, do you know if you are in compliance with their regulations?
There are many regulations globally that could impact the sale of your product. If your product is an article, you may not have to be concerned about hazard communication or chemical regulations, but you still should be aware of and comply with other regulations. Your product could be subject to Banned and/or Restricted lists. It is essential to understand what constituents are in your article, and whether it contains any substances of very high concern (SVHC). If your article contains SVHCs, you may be subject to various regulations, registrations, and communication requirements. The Organization for Economic Cooperation and Development (OECD) provides a table of restricted substances lists and related laws and regulations organized by geographic scope.
For all products, whether chemical, mixture, or article, you may also need to consider transportation laws, waste directives, Conflict Minerals laws, and Food Contact laws. What about the downstream uses of your product? Depending upon the product’s application, there are regulations that could be relevant, such as for Consumer Products, Children’s Products, Agricultural Products, Pharmaceutical Products, and Medical Products.
The global regulatory landscape can be complex and challenging.
If you require help navigating, contact us at Strategic Realm Consulting. We will work with you to develop cost-effective and risk-based approaches. Then we will teach you how to maintain your processes, so you can save money in the long run. Regulatory compliance doesn’t have to be expensive, but non-compliance will certainly be!