Chemical registration in Serbia: why 40 products still means 40 data entry sessions

Imagine you have all the data. Every safety data sheet is up to date, every CAS number has been checked, every share of imports and domestic production is known. The company is well organised and the team is ready. Now January arrives, the period for notifying chemicals to the Serbian Chemicals Register, and the only thing left is to submit that data.

In Serbia, this still means 40 separate sessions in the portal. For each product separately: cloning the dossier from the previous year, opening each one individually, correcting quantities, changing the shares of imports, exports or domestic production, updating the composition or classification where something has changed. Even when a company has all its data perfectly prepared, the eIRH portal offers no shortcut. Every dossier needs manual attention.

There is a system that solves this problem differently. It is not a fantasy or a pilot project. It exists and it works.

What chemical notification looks like in Serbia today

Companies that place chemicals on the market are required to notify them to the Chemicals Register kept by the Ministry of Environmental Protection. Notification is submitted through the eIRH portal, and for each product a Chemical Dossier is filled in, consisting of several steps: general data and the origin of the chemical, the method of use and the activity code, labelling elements under the CLP/GHS rulebook, chemical composition, volatile organic compound content and attached documentation, including the safety data sheet.

The portal works. Data is entered digitally, and that is progress compared with paper notification. The system also has useful features, such as copying dossiers from previous years and grouping chemicals into coherent groups.

However, the essential logic of the work has remained unchanged: one product, one entry session, one dossier at a time. For a company with a portfolio of 40 active chemicals, every annual notification requires 40 separate passes through the wizard, no matter how well the data has been organised in advance.

The key thing to understand is this: preparing data and submitting data in eIRH are not separate processes. They are fused into one manual, repetitive process.

What is happening in Sweden?

The Swedish Chemicals Agency (KEMI) keeps a Products Register in which products placed on the market in Sweden are recorded. The obligations are almost identical to the Serbian ones: who imports what, in what quantities, what the chemical composition is, what the classification under the GHS system is.

The difference lies in how the data is delivered to the system.

In addition to manual entry, the KEMI web portal offers the option of importing data via CSV files. The user downloads a template in CSV format, fills it in in Excel or another editor and uploads it to the portal. The system imports everything at once, creates drafts for each product, and the user then reviews and submits them.

The entire notification process for 50 products can take as long as notifying one, provided the data has been organised in advance. And the CSV file can be prepared and supplemented throughout the year.

Two files, the entire portfolio

The KEMI registration system uses two basic CSV files.

The basic data file has 19 columns, and each row represents one product. It contains the product name, the customs tariff code, availability to consumers, origin (domestic production, import from the EU, import from third countries), the export percentage, function codes, areas of application, classification by H-statements, hazard labels under the GHS system, volatile organic compound content and PFAS status.

The composition file contains the chemical composition for all products together. Each row is one component of one product. The columns cover the CAS number, the EC number, the substance name, concentrations and additional flags such as preservative, active substance or impurity. If one product has eight components, it has eight rows in this file with the same product identifier. For a portfolio of 50 products with an average of ten components, the entire composition is submitted in a single file with 500 rows.

For the annual quantity report there is a third file with just four columns: product identifier, name, article number and quantity in tonnes.

Where the real problem is: architecture, not format

This is where we reach a key difference that is easy to overlook. The difference between eIRH and KEMI is not only that one uses web forms and the other CSV files. The difference is that in eIRH, preparing and submitting data are the same process, while in KEMI they are completely separate.

In eIRH, a company can have all its data updated and checked, but notification still requires going through the portal product by product. Changing a single number, for example the total quantity or the share of imports, means opening the dossier, navigating through the wizard steps and typing it in manually. This is repeated for every product affected by that change.

In KEMI, the same change means opening the file, changing the value in the relevant row and uploading the updated file. One step for one change, no matter how many products the change affects.

This is not a question of comfort or user experience. It is a question of the time a team spends on administrative data entry instead of checking the accuracy of classifications, analysing chemical composition or aligning with new regulations.

Preparation outside the deadline, submission within it

Manual entry through a form is by its nature tied to the notification period. Notification begins when the deadline starts to press. Each dossier is filled in on the go, data is checked at the last minute and errors are spotted late.

A CSV file works differently. It can be prepared weeks or months before the deadline. Data is collected gradually, at a pace that suits the company or the consultant managing the portfolio. When new safety data sheets arrive, the corresponding rows are updated. When a classification changes, the change is made in one place and applies to exactly the row that is relevant. The file is a living document that tracks the state of the portfolio throughout the year.

When the notification deadline arrives, the work is essentially done. What remains is a final check and the upload. For a consultant managing several clients at the same time, this is not a marginal advantage. It is the difference between a controlled process and rushed data entry before the deadline.

The effect on consultants and in-house chemical advisers

Chemical advisers who manage registrations for several clients at the same time face this problem on a larger scale. Each client with a portfolio of 30 or 50 chemicals means hundreds of manual steps in the portal. The annual notification cycle lasts days, and often weeks, depending on the size of the portfolio and the complexity of the changes.

By contrast, the structured format KEMI offers opens up the possibility of managing data efficiently. Data that has been organised and verified once can be used as the basis for the following years, and changes are introduced in a targeted and precise way.

For in-house chemical advisers, this means that if the last import was completed in October, the final figures can be entered at that point. By the time the registration deadline arrives, the data will have been ready for submission for months.

The infrastructure is in place

The eIRH portal exists. The registration system works. The Serbian Law on Chemicals and the Rulebook on the chemicals register and the chemical dossier define which data must be submitted. That data is essentially the same as what KEMI collects.

KEMI did not invent anything new. It organised the same data into a structured format that can be imported into the system. A substance database already exists in eIRH and is searched by CAS and EC numbers when each ingredient is entered. The same mechanism could be used to automatically map data from a CSV file to the corresponding entries in the code list.

The move from paper notification to the eIRH portal was the first and bigger step. It was a shift in culture and process, not just in technology. Introducing CSV file import would be a logical continuation, aimed at the efficiency of those who use the system every day.

Conclusion

The question is not whether Serbian regulatory obligations are wrong or too demanding. The question is whether there is a better way to deliver the same, accurate data to the system.

The answer exists, and it is applied in a country with a similar regulatory framework and similar obligations. Companies in Sweden notify chemicals with two files and two uploads. Companies in Serbia go through the portal dossier by dossier, even when all the data is already known and checked.

For any company that each year changes only the quantities and the occasional composition detail for 40 chemicals, this remains 40 separate sessions. No exceptions and no shortcut.

That is time that could be spent on regulatory analysis, alignment with new regulations or preparing clients for upcoming changes. Instead, it is spent navigating a wizard.

If you have experience with eIRH notifications, one question naturally arises: have we solved this problem as well as we could have?

References:

• eIRH
• Rulebook on the chemicals register
• Chemical dossier
• Dossier for a chemical already entered in the register
• KEMI Products Register