The Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), is in force since 01/06/2007 . As the first step of its long process, REACh has imposed the pre-registration of all “phase in” substances between 01/06/2008 e il 01/12/2008 to all producers or importers based in UE.
On 01/09/2008 the “TITANSTUC S.p.A.” has appointed as its “Only Representative” (OR) the Baerlocher GmbH, located in the European Union (hereafter the EU) at Freisinger Strasse 1, Unterschleissheim – Germany. On 11/11/2008 the Baerlocher GmbH has pre-register all substances used in our product portfolio, including those substances that are already in the annexes IV and V (Commission Reg. (EU) N ° 987 / 2008) and that probably will not need any registration.
After pre-registration, depending on tonnage and on the specific classification, the registration of a first part og substances (on 01/12/2010) and second one (on 01/06/13) has followed. The remaining substances will be registred within 2018.
The “TITANSTUC Sa” is located in a country outside the EU and for the production of its preparations “TITANSTUC S.p.A.” uses and is going to use substances from the EU, as such or as components of preparations, registered or being registered, according to their classification and volumes involved. For this reason, our customers based in EU are not IMPORTERS, but RE-IMPORTERS according to the Article 2, paragraph 7, point C of Regulation (EC) No 1907/2006. This article clearly shows how all registered substances, which are exported to countries outside the EU and re-imported into the EU, are exempt from Titles II, V and VI of the EU Regulation 1907/2006 and therefore are exempt from a double registration. Following these considerations, a customer based in EU purchasing products from “TITANSTUC Sa” is not an IMPORTER, but a RE-IMPORTER and therefore he is exempt from the application of Art. 40 of Regulation (EC) No 1272/2008 (hereafter CLP), from the notification to the ECHA on the identity, classification and labeling of a hazardous substances, as such or as contained in a mixture, in a quantity that determine its classification as hazardous.
We will keep constantly informed the Customers about further developtments, updates of the a.m. Regulation and registrations. We will try to do our best to mantain in portfolio all alternative substances we could, if some Customer will decide to not proceed in the registration.
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