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Referenced suggestions for fireworks enterprises on REACH--International Fireworks Association(IFA)

Referenced suggestions for fireworks enterprises on REACH

                                                                                          International Firework Association
                                                                                                     16th Sep 2008
To all members of IFA:
Recently, there are many ideas for REACH Articles (Regulation for Registration, Evaluation, Authorization and Restriction of Chemicals) that confuse the firework enterprises for it. Therefore, IFA Secretariat put a deep understanding and research for it, the referenced suggestions for fireworks enterprises to making decision as below:
ⅠIs it necessary to take REACH registration for fireworks enterprises?
Chemical compositions of fireworks products consist of chemical materials and it will display out with the intentions during the process, therefore, according to the relevant regulations of REACH Articles fireworks belong to chemical substance of REACH registration. The chemical articles in REACH scope without registration can not import to European countries from 1 Jan 2009. But not all the chemical compositions of fireworks need to registration; there is unnecessary item for registration, when the every non European export enterprises or every European import enterprises with its total chemical compositions less than 1ton.
Ⅱ When the enterprises should take registration? 
According to the regulations of REACH Article, the pre-registration for every enterprise start from 1st Jun 2008 to 30th Nov 2008. The enterprises which take the pre-registration could enjoy 3 to 10 years registration buffering period. It’s estimated that the total weight of every chemical compositions for every export or import enterprises to European market are less than 100 tons, therefore, the fireworks enterprises could enjoy 10 years registration buffering period after take pre- registration. Say, your company has taken the pre-registration, you could make formal registration at any time before June 2018; otherwise, and you must make formal registration if you haven’t taken pre- registration before the 30th Nov 2008. It’s very expensive for the formal registration.   
Ⅲ  Is it necessary for you to take REACH registration?
According to the regulations of REACH Articles, the chemicals import to European Union, as long as you finish the any circle of registration for the chemical supplying chains, your goods will be accepted. For instance, the export supplying companies include: Manufacture or Sales Companies of Chemical Material, Manufacture or Export Fireworks Companies, European Import Fireworks Companies etc. When your goods export to Europe, any circles of your relevant goods in supplying chains has been registered that you may not take registration.   
At present, as we know that majority European Union import fireworks companies will take registration, if you considered that your company only makes business with the registered import companies, then you may not take registration. Therefore, it’s necessary to make good communication with your customers.
But, if you considered that you will make direct sales of fireworks in the future or you will make business with non registration import companies in European Union, in that case you’d better take registration.
Ⅳ What’s the advantage and disadvantage between registration and non-registration?
Advantage of registration: companies can get more initiative right in the fireworks market of European Union, and left more options for customers and supplying chains.
Disadvantage of registration: You may spend amount of money on pre-registration, and then spend much more money on formal registration (of course, if you take pre-registration and you may quit the formal registration in the future). Because the pyrotechnic chemicals consist of many kinds of compositions, according to our estimate there are about 20 kinds of materials need to register, furthermore, these materials need to register one by one.
Advantage of non registration: if you made a good communication with your customers who taken the responsibility of registration, and then you may not take registration and save amount of money.
Disadvantage of non registration: you have no initiative right in the foreign trade with European Union. Additional, if there’s no any registered company in your whole supplying chains, and you will lose the European market.
Ⅴ How to look for the agency for the registration?
As the REACH Articles, only the company registered in European Union can take the right of agency for pre-registration and formal registration. General non European Union fireworks enterprises have no capacity to registered company in European Union, but it can register in the sole agency corp. If you plan to pick the sole agency, you must pay attention to whether it registered in European Union and whether it owned strong activity scope, because the agency will instead of your extending maintenance, and delegate your company to participate SIEF symposium, furthermore, you may get more profits in the apportionment of registered fees.
Ⅵ How much the registered fees?
No charge of pre-registration which takes registration in European Union, but the sole agency company may charge the fees for agency and extending maintenance. As the recent status: every item of chemical materials for pre-registration is about 4,000RMB.
We hope the suggestions will help you. If you want to get more information please contact with IFA Secretariat.     
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