The purpose of Regulation 2019/1148 is to avoid improper use of products that could be potentially used to produce explosives. It will be effectivee starting from February 1st 2021.
The products that fall under this regulation are the substances reported in Annex I in quantities exceeding the limit value such as nitric acid >3%, sulfuric acid >15%, hydrogen peroxide >12% etc.
The requirements that needs to be adopted for producers/sellers are different depending if the substance is sold to privates/online or to professional users. Clearly they are much more stringent in the first case.
Not selling to private individuals and/or online, but only to professional users simplifies considerably the requirements but does not exempt from the regulation: in fact, Article 8. paragraph 2 specifies that as an “economic operator who sells an explosives precursor to another economic operator “is required to verify how he intends to use it, and he must do the same if he wants to resell it. In summary, every time one of these products is sold, a series of information must be requested (contained in Annex IV) unless the aforementioned declaration has already been made within the year preceding the date of such transaction for a similar one: a declaration is required for each customer for each product that falls under this regulation, with annual frequency.
TEAM mastery suggests having a list of all the products that fall within the regulation and ask each customer to fill in attachment IV for the first order of each year, possibly for all products purchased regularly based on the history and to update them at the beginning of each subsequent year.
TEAM mastery is at your disposal for clarifications and special cases upon request.