Applications for authorisation can cover uses of an authorised substance of very high concern (SVHC) by the applying company, by downstream users further down in the supply chain, or both.

Downstream users covered by an authorisation granted to an actor up their supply chain must notify ECHA of their use. This requirement is based on Article 66 of REACH.

ECHA keeps a register of downstream user notifications and passes the information to the Member State competent authorities.

The graph below gives an overview of all downstream user notifications received to date. For completeness, there is also a table showing the number of authorised uses per SVHC. ECHA updates this information quarterly.

The information presented is based on notifications received from downstream users. Therefore, inaccuracies may exist. See ECHA’s legal notice for further information.

All uses and authorisations in sites in the United Kingdom are not being counted.

Background:

Authorisations to use SVHCs can be granted if an applicant can demonstrate that the risk from the use of the substance is adequately controlled, or that the socio-economic benefits outweigh the risks and there are no suitable alternatives. All authorisations are subject to a time-limited review period. The authorisation process aims to ensure that SVHCs are progressively replaced by less dangerous substances or technologies where technically and economically feasible alternatives are available. For more information about the authorisation process, follow the links available on this page.

For more information regarding the public version of the notification register and its aims, see ‘Information from downstream user notifications made public by ECHA’.

 

Public data on downstream user notifications

This document contains all public information from downstream user notifications. It is organised in four tabs and contains data for all substances for which upstream authorisations have been granted. We hope this will help our stakeholders gain better insights on the data. We plan to release more data in the future.

The first tab “Notified uses” contains all public information submitted by downstream users. Users can flag some information as confidential.

The second tab “Authorised uses” contains all the data on authorisations that have been granted by the Commission (ref. https://ec.europa.eu/docsroom/documents/45356). Downstream users can voluntarily notify how many workers are exposed to the substance.

The third tab “Uses per country” provides a breakdown of all authorised uses and uses notified by downstream users in the EU.

In the fourth tab “Usage over time” there is a collection of charts that display the number of uses for which an authorisation has been granted and the number of uses notified by downstream users. Only substances for which upstream authorisations have been granted are included.

Includes only substances for which there are upstream authorisations, i.e. authorisations applied for by the manufacturers and importers of chemicals covering their downstream uses and sometimes their own use.

Status of received notifications

31 December 2022 Downstream
uses notified (active)		 Uses for which
own authorisation is held*)		 Total authorised uses
Bis(2-ethylhexyl)phthalate (DEHP) 8 2 10
bis(2-methoxyethyl) ether 2 11 12
Chromium trioxide 1690 106 1724
Dibutyl phthalate (DBP) 10 4 14
Dichromium tris(chromate) 288 6 284
Hexabromocyclododecane (HBCDD) **) 0 0 0
Lead chromate molybdate sulphate red ***) 0 0 0
Lead sulfochromate yellow ***) 0 0 0
Pentazinc chromate octahydroxide 89 6 84
Potassium chromate 1 2 3
Potassium dichromate 113 9 113
Potassium hydroxyoctaoxodizincatedichromate(1-) 226 10 223
Sodium chromate 14 9 22
Sodium dichromate 213 39 250
Strontium chromate 583 23 562
Trichloroethylene (TCE) 207 16 223
4-(1,1,3,3-tetramethylbutyl)phenol, ethoxylated (OPE) 5 58 31
4-nonylphenol, branched and linear, ethoxylated (NPE) 111 6 86
Total 3560 307 3867

*) These are uses for which companies have an authorisation themselves. They also include authorisations held by companies whose applications covered downstream uses, as the same uses are permitted to also take place at the authorisation holders’ sites. However, it is possible that in practice the authorisation holders do not themselves use the substance.

**) All authorisations for HBCDD expired on 21 August 2017.

***) All authorisations for Lead chromate molybdate sulphate red and Lead sulfochromate yellow have been refused. The decision refusing these 8 uses replaces the effect of the previous positive Decision initially granting authorisation for the use C(2016)5644, which was annulled by the General Court in the judgment of 7 March 2019 in case T-837/16. The annulment was confirmed by the judgment of 25 February 2021 of the Court of Justice in the appeal case C‑389/19 P, which maintained the effects of Decision C(2016) 5644 until the adoption of a new Commission Implementing Decision on the application for authorisation.

The number of downstream user notifications is counted as follows:

  • Each use per site is counted as a separate notification, and the total number of active notifications (uses) is reported. So, if there are four uses of a substance at one site, and three (same or different) uses at another site, this is counted as seven notifications.
  • If the same use is notified under different authorisation numbers, it is counted only once. Two uses for the same substance are considered to be the same if the use name/titles are exactly the same. As an example, use 2 of the “CTAC” decision and use 2 of the REACHLaw decision are considered to be the same because they have the exact same name/title.
  • If ECHA subsequently receives an update of a notification showing that the substance is no longer used at a site (ceased or substituted use), the number of uses at that site will be deducted from the current total number of notifications.
  • Uses for which the authorisation’s review period has expired and no review report has been submitted are deducted from the counts (this also applies to the uses of authorisation holders).