[Alt-photo] Antwort: Re: Update EU-Regulation 98/2013

udo.schnitzbauer at access.uzh.ch udo.schnitzbauer at access.uzh.ch
Thu Mar 24 06:44:55 UTC 2016

Dear List:

a) REACH (Sunset-Dates)

I got contact with a German lawyer who knows EU and German Chemical Law. He said that a assessment of the situation will be 10 working hours for him. So will pay the fees (2500 Euro) and ask him this questions:
a) Is there at all a way to get authorization?
b) Are artists and persons working as a freelancer targeted from REACH? 
c) What is the case with private persons, which are making gum- and bromoil prints and sporadically selling a few prints?
d) What is the case with people which are making workshops? Because in the German translation REACH regulation you will find following definition:
[...]12. Inverkehrbringen: entgeltliche oder unentgeltliche Abgabe an Dritte oder Bereitstellung für Dritte. Die Einfuhr gilt als Inverkehrbringen;[...]
The term "Bereitstellen" means in English: to provide sth.
Here the English definition:
[...]12. placing on the market: means supplying or making available,whether in return for payment or free of charge, to a third party. Import shall be deemed to be placing on the
For me it seems that if you make a gum printing workshop even if I do not take money, you will be in targeted with REACH....

If you have other questions or aspects. please write it to me....

b) New developments 98/2013:

[...]3) Substances proposed for addition into Annex I
The United Kingdom presented its proposal to transfer Sulphuric acid (in concentration of 40 % w/w or higher) into Annex I. This amendment can only be introduced via the adoption by the Commission of a legislative proposal. The main consumer products identified were some drain cleaner products in niche markets where the number of sales are very low.
In the ensuing discussion, Denmark and Sweden noted that they already restrict sulphuric acid over specific concentrations, and that they have not experienced any problems in doing so.
Sulphuric acid is scheduled under the Drug Precursors Regulation. It is subject to the reporting of suspicious transactions in that context, to export authorisations to third countries in some instances, and to a registration requirement also in some instances.


That will affect in the first line private persons but the recent developments indicate that this regulation will be put in force for business use, too. 

c) I wrote a mail to the admin of http://holowiki.org/wiki/Main_Page and asked for support for the dichromate-sunset-date-issue....

d) Once again:

People which are interested in this whole issues, please register at https://ivntforum.phoerauf.de/ and write to me at "udos  followed by an @ sign followed by hawaii.edu" with your chosen pseudonym, because I have to activate every user.

Thank you for your attention..


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