Regulation (EU) 2019/1148
New EU regulation massively restricts sales of sulfuric acid.
Dear business partner,
Also the new year 2021 brings again some changes and innovations...
We would like to take this opportunity to inform you about the new Regulation (EU) 2019/1148 of the European Parliament and of the Council of 20 June 2019 on the marketing and use of explosives precursors. Unfortunately, this law will now directly affect us as battery wholesalers in the future, as sulfuric acid (CAS No. 7664-93-9) has been included in ANNEX I / „Restricted precursors for explosives“ along with other chemicals.
IMPORTANT: Batteries in general are not affected by this law because they are considered a product. It only concerns sulphuric acid sold in bulk such as acid packs for motorcycle batteries or separate acid in containers etc.
Furthermore, a distinction is made between sales to end consumers (B2C) or sales to commercial customers (B2B). With the new law, which comes into force on 01.02.2021, it is now prohibited to sell sul-phuric acid with a limit value of more than 15% w/w to end customers in the B2C business. According to the EU law, they would need a special permit to purchase it. However, such a licensing procedure is not yet planned in Germany, which means that no more sulphuric acid may be sold to end customers!
This means that all batteries must now be filled on site if they are not delivered filled and charged. In addition, the staff in the sales department must be informed about this law and must be trained accordingly. Sulphuric acid in bulk may no longer be sold to the end customer.
The sale of sulphuric acid in the B2B sector is also subject to this law. The relevant information ab-out this new regulation must be passed on within the supply chain. In addition, a declaration must be obtained from each commercial customer on the proper use of the sulphuric acid, so that a sale is still possible in future.
T his declaration is then valid for one year. Therefore we have now decided to obtain this declaration from all our customers always at the beginning of the year, so that during the year a smooth and fast processing of your orders is possible.
You will find this declaration in the annex. We have prepared it especially for you so that it can be com-pleted quickly and easily. First and foremost, according to this law it is important that there is a plausib-le use for the product sulphuric acid, which in our industry is naturally derived from our daily business with lead-acid batteries. The aim of the law is to document the sales of sulphuric acid and other poten-tially usable chemicals and, if necessary, to detect misuse in a timely manner.
We are fulfilling our obligation as a battery wholesaler and therefore want to obtain this declaration properly from you. Therefore, we ask you for your assistance, so that the annoying „paperwork“ is already done at the beginning of the year. Please complete the enclosed declaration and send it to us as soon as possible. This is the only way we can continue to deliver batteries with acid packs to you quickly and without complications. Without declaration no more delivery is possible!!!
Please also consider that you also have the duty to pass on this information within the supply chain, to instruct your staff accordingly and, if necessary, to obtain explanations from your customers or to stop selling sulphuric acid to private customers (filling the battery on site!!!).
With kind regards
"AUVIRAS" UAB administration
Regulation (EU) 2019/1148 of the European Parliament and of the Council of 20 June 2019 on the marketing and use of explosives precursors.