Environmental Protection: Chemicals
EU chemicals policy - REACH
Questions and answers: Downstream users
What are the duties of downstream users under REACH?
In brief, a downstream user (DU) will be required to:
- Inform its supplier(s) of “identified uses” it wishes to have covered in a Chemical Safety Assessment (CSA). In such cases, the DU must provide sufficient information to the supplier to enable them to develop an exposure scenario (ES) for the identified use. Alternatively
- Implement the risk management measures set out in an ES annexed to a safety data sheet (SDS) for identified uses, or follow the DU’s own CSA
- Prepare SDSs, including the ES as an Annex, for further downstream users (as set out in Annex XII)
- Comply with any restrictions on manufacture, placing on the market and use of substances and preparations (as set out in Annex XVII)
- Use authorised substances, in the same supply chain as the person receiving the authorisation, as set out in the authorisation and communicated in the supplier’s SDS or apply for authorisations for substances listed in REACH Annex XIV
What if a DU does not want to identify a use to its supplier?
A DU can perform its own CSA for “non-identified uses”. It must then separately notify these uses to the European Chemicals Agency (ECA). In this way, a DU can choose to keep its use of a substance confidential or decide to use a substance outside the conditions described in an exposure scenario communicated in a SDS. A DU CSA consists of developing the exposure scenarios for their intended uses and, if necessary, a refinement of the supplier’s hazard assessment.
Page published: 11 May 2007
