The life cycle of an explosive is from the point of manufacture to the point of use or destruction.
IToER 2013 requires manufacturers or importers of explosives to mark explosive items with a unique identification. The unique code must be marked on each individual item, so each individual shape charge would need its own individual number.
ITOER 2013 does not apply to civil use explosives manufactured or imported before 5 April 2013 which can be placed on the market and transported throughout the EU provided that all other requirements of Directive 93/15/EC are met. ITOER 2013 only applies to civil use explosives placed on the market after 5 April 2013.
If the abbreviated name is a commonly known and recognisable trade name, this would be acceptable. The abbreviation should not make it impossible to identify the manufacturer.
The finished JPG should be given a single new identification and relevant records kept to detail the incorporation of the shaped charges into the JPG. If the JPG is created on the site of intended use, marking the JPG would not be necessary provided the item is not transported elsewhere.
Where manufacturing sites are located outside the EU, the procedures of Article 3(5) of Commission Directive 2008/43/EC should be followed. However, in cases where the overseas manufacturer is also established in the EU, he could contact the national authority of the Member State in which he is established or of first import and obtain a single code for the manufacturing site to be used for all imports into the EU. The manufacturer established in the EU would assume responsibility for compliance with the Directive for all those imports, including in particular the obligations of undertakings in relation to record-keeping.
In all other cases where the manufacturing site is located outside the EU, the importer of the explosives will have to obtain a code in accordance with the second subparagraph of Article 3(5) of the Directive.
To further reduce the administrative burdens, and also in cases where the overseas manufacturer is not established in the EU, the imports need not physically go through the location of the importer or of the EU legal entity of the manufacturer, but any point of entry, provided that they are handled in line with the single authorisation for simplified procedures (SASP)/centralised customs clearance used throughout the EU under customs legislation, whereby the import paperwork is submitted in one Member State, but the products can be shipped directly to another Member State or States (with the customs authorities there not requiring additional paperwork).
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