- Communication in the supply chain
- Downstream users
- About downstream users
- Downstream user responsibilities
About downstream users
About downstream users
All downstream users
When downstream users receive a safety data sheet (SDS), they need to identify and apply appropriate measures to adequately control the risks. When it is an extended SDS, they must additionally check whether the exposure scenario covers their own use of the substance and their conditions of use or take alternative action.
This must be done within 12 months of receiving an SDS for a registered substance. Downstream users need to report to ECHA within six months of receipt of the safety data sheet (SDS) for a registered substance if their use is not supported and they prepare a DU CSR or claim exemptions.
For more information, see the section on Checking your use, "eGuide on safety data sheets and exposure scenarios" and "Practical Guide 13: How downstream users can handle exposure scenarios".
Downstream users need to inform suppliers if the recommended risk management measures are inappropriate and whenever new information on hazards becomes available. This responsibility is outlined in Article 34 of REACH and should be undertaken without delay.
Downstream users are also entitled to provide information regarding their uses of a substance (or substance in a mixture) to suppliers of substances. This enables registrants to include these uses in their chemical safety assessments. See "REACH registration and downstream users" for more information.
Chemicals of concern may be subject to regulatory risk management such as authorisation, restriction or harmonised classification. Downstream users are advised to keep informed on the regulatory activity to make sure they are aware of their responsibilities that apply now or in the future. They are encouraged to engage in public consultation to provide information necessary for decision making by regulators.
Downstream users who place substances and mixtures on the market must classify the chemical according to CLP. They may use the classification provided to them by their supplier or may classify it themselves. If downstream users use a classification that is different to that of all of their suppliers, then they need to report this to ECHA.
When a substance or mixture is classified as hazardous, it must be labelled and packaged accordingly.
Downstream users who supply hazardous substances, as such or in a mixture, have to communicate information regarding the safe use to their own customers. This should be in the form of a safety data sheet or otherwise, as required.
Downstream users need to update this information without delay if:
- New information on risk management measures or hazards becomes available.
- An authorisation was granted or refused.
- A restriction has been imposed.
If downstream users produce or import an article containing a Candidate List SVHC in a concentration above 0.1 % (w/w), they must give sufficient information to allow recipients of the article to use it safely. The information should be provided on supply to downstream users and, if requested by consumers, within 45 days of receipt of the request.
In addition, if the Candidate List substance is present in those articles in quantities totalling over one tonne per producer or importer per year, the downstream user should notify ECHA within six months of inclusion in the Candidate List.
Substances intended to be released from an article in quantities totalling over one tonne per year during use may need to be registered.