Subject: information requested in order to export chemicals from France to Spain.
From: expost@dpwcolors.com
Sent:
Monday, November 23, 2015 4:59 PM
To:
bfernandez@aveq-kimika.es
Dear Borja,
Our company
is producing pigments and other chemicals in France and we are working with
XXXXX XXXXX.
Very
shortly, we will have to ship goods to their factory in Spain and we are
wondering if we have to make some registrations with you in order to export.
XXXX XXXX
asked us to contact poison control center to be ready.
Hope you
will be able to help us and answer our question.
Thanks
Cordialement
/ Best regards
EXPORT
DEPARTMENT
DPW
COULEURS S.A.S.
20 Cours
Michelet, 92800 Puteaux, France
----------------------------
Hello,
thank you for contacting us.
First of
all, let me introduce ourselves, you are writing to AVEQ-KIMIKA, we are a
chemical companies association from the Basque Country region, we serve to over
125 associated companies and we offer our services as regular consultants to
non-associated companies as well. For your interest, we have been working in
regulatory affairs area for the past 15 years, including DSD, DPD, Biocides,
REACH and CLP.
Said that,
let me clarify how things are going in Spain regarding CLP article 45
notification (regulated in France by Décret 2014-128 du 14 février 2014 and in
Spain by Orden JUS/836/2013):
1. Scope:
Only mixtures classified as dangerous (health and/or physical categories)
should be notified. So, i) substances, ii) not dangerous mixtures and iii) only
dangerous for environment mixtures; are exempted.
2. How to
notify:
Right now
in Spain we got two alternative systems:
a) Ordinary
notification: mixtures classified as dangerous (health and/or physical) should
be notified to "Instituto Nacional de Toxicología" (INT) following
CLP art 45. This notification includes:
- SDS
- Label
-
Toxicological sheet where full composition should be indicated.
In order to
make this notification you should use the software GesFicCom that you can
download from INT website. Each
notification is subject to fee payment (30,00€ or less being an SME).
b)
Pre-Notification: In the very last minute of last June, authorities gave us a
transition period through this regulation:
http://www.boe.es/boe/dias/2015/05/30/pdfs/BOE-A-2015-5950.pdf
When
mixtures are for industrial use only (REACH SU3), instead of making the
ordinary notification you could make a "pre-notification" and you do
not neet to make the ordinary notification till 1st june 2017.
In order to
make this pre-notification, you need:
- SDS
- Label
- Excel
sheet where the trade names are indicated (in this case, no full composition
nor fee applies)
If this is
your case (only industrial use) I highly recommend you go this way and forget
by now about the ordinary notification, you could find all the information
here: https://goo.gl/D6xtxi
If you find
making the pre-notification too complicated, we could send the information on
your behalf.
In any
case, let me know any question you got,
Regards,
Mr. Borja
Fdez. Almau
Abogado
colegiado / Lawyer Bar # 6997
Área de
Tutela de Producto - Regulatory Affairs
AVEQ-KIMIKA
Gran Vía,
50 - 5º
48011
BILBAO (Spain)
Tel: +34
944002800
Email:
info@aveq-kimika.es
www.aveq-kimika.es
Volver a: www.aveq-kimika.es
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