REACH,Regulations,Regarding,Pr business, insurance REACH Regulations Regarding Promotional Pens - Latest Legisl
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SummaryImporters of large-volume promotional pens orpromotional products of any description containing ink need to be awareof this piece of new legislation. E.E.C Regulation 1907/2006 came intoforce on 1st June 2008 and the important features for pen importers areto quote... " Registration is compulsory when the substance in questionis normally released when the product is used" which of course for ourindustry refers to the ink in the refill. Furthermore the regulationapplies "when the ink "is present in those products in quantitiestotalling over 1 tonne per producer or importer per year."Now atonne of ink sounds a lot, but when annual quantities of importedpromotional pens are in their millions, more than an average of 0.1g ofink in each pen means the total is easily exceeded. If you think youmight need to register, in all probability you won't need to becausethere are exemptions to the rules and other conditions that may makeregistration unnecessary.Firstly, reputable documental inkmakers of any size will have already registered the relevant substancesand importers of promotional pens or other promotional items containingdocumental ink can quote the registration details of their supplier.Secondly, if the refills are exported and re-imported as part of aPromotional Pen, this too is exempt provided that the original re-fillsupplier already has its component raw materials registered for REACH.Finally, there are specific exemptions which means there is norequirement to register the majority of ingredients contained indocumental inks.Technical DetailThis is where it getscomplicated, documental inks are not single substances, they are acomplex mixture of pigments, resins, solvents and additives. Thedefinition of a substance that needs registering within the legislationis " A chemical element and it's compounds in the natural state.excluding any solvent which may be separated without affecting thestability of the substance or changing its composition" Now, since amajor component of the ink is solvent, this is excluded. Also, so arepolymers, and since the other major component of an ink is a resin,(which in turn is a polymer) then these too are exempted. That leavesthe additives, and some of these could also be exempted on the basisthat " the estimated risk is negligible" e.g water which is used ininks for Fountain Pens. .So, on balance for more than 80% ofthe weight of the ink, the chemicals do not fall within the scope ofREACH. In the unlikely event that an importer is buying in tens ofmillions of Pens , and not getting the inks from an already REACHRegistered supplier, to calculate whether or not the substance needsregistering for REACH, the importer will need the exact formulation ofthe ink, which of course is the intellectual property of the owner andclosely guarded, and is likely to be refused.ConclusionSo,in a nutshell, nothing to worry about for small importers ofpromotional pens, promotional items or business gifts containingdocumental and even large ones if the imported pens contain inksproduced by a REACH Registered supplier. If you are a major importerbuying in millions of pens and don't have these safeguards in place,watch out. The enforcement agency is the Health and Safety Executive. Article Tags: Promotional Pens, Promotional Items
REACH,Regulations,Regarding,Pr