| Summary | | | | are not single substances, they are a complex |
| Importers of large-volume promotional pens or | | | | mixture of pigments, resins, solvents and additives. |
| promotional products of any description containing ink | | | | The definition of a substance that needs registering |
| need to be aware of this piece of new legislation. | | | | within the legislation is " A chemical element and it's |
| E.E.C Regulation 1907/2006 came into force on 1st | | | | compounds in the natural state. excluding any solvent |
| June 2008 and the important features for pen | | | | which may be separated without affecting the |
| importers are to quote... " Registration is compulsory | | | | stability of the substance or changing its composition" |
| when the substance in question is normally released | | | | Now, since a major component of the ink is solvent, |
| when the product is used" which of course for our | | | | this is excluded. Also, so are polymers, and since the |
| industry refers to the ink in the refill. Furthermore the | | | | other major component of an ink is a resin, (which in |
| regulation applies "when the ink "is present in those | | | | turn is a polymer) then these too are exempted. |
| products in quantities totalling over 1 tonne per | | | | That leaves the additives, and some of these could |
| producer or importer per year." | | | | also be exempted on the basis that " the estimated |
| Now a tonne of ink sounds a lot, but when annual | | | | risk is negligible" e.g water which is used in inks for |
| quantities of imported promotional pens are in their | | | | Fountain Pens. . |
| millions, more than an average of 0.1g of ink in each | | | | So, on balance for more than 80% of the weight of |
| pen means the total is easily exceeded. If you think | | | | the ink, the chemicals do not fall within the scope of |
| you might need to register, in all probability you won't | | | | REACH. In the unlikely event that an importer is |
| need to because there are exemptions to the rules | | | | buying in tens of millions of Pens , and not getting |
| and other conditions that may make registration | | | | the inks from an already REACH Registered supplier, |
| unnecessary. | | | | to calculate whether or not the substance needs |
| Firstly, reputable documental ink makers of any size | | | | registering for REACH, the importer will need the |
| will have already registered the relevant substances | | | | exact formulation of the ink, which of course is the |
| and importers of promotional pens or other | | | | intellectual property of the owner and closely |
| promotional items containing documental ink can | | | | guarded, and is likely to be refused. |
| quote the registration details of their supplier. | | | | Conclusion |
| Secondly, if the refills are exported and re-imported | | | | So, in a nutshell, nothing to worry about for small |
| as part of a Promotional Pen, this too is exempt | | | | importers of promotional pens, promotional items or |
| provided that the original re-fill supplier already has its | | | | business gifts containing documental and even large |
| component raw materials registered for REACH. | | | | ones if the imported pens contain inks produced by a |
| Finally, there are specific exemptions which means | | | | REACH Registered supplier. If you are a major |
| there is no requirement to register the majority of | | | | importer buying in millions of pens and don't have |
| ingredients contained in documental inks. | | | | these safeguards in place, watch out. The |
| Technical Detail | | | | enforcement agency is the Health and Safety |
| This is where it gets complicated, documental inks | | | | Executive. |