Summary of obligations

This is a summary of the main activities and timelines of downstream users. The general downstream users obligations are laid down in Articles 37-39 (Title V) of REACH unless otherwise specified.

Inform supplier of a use when the substance is not yet registered

The downstream user needs to make a request twelve months before the registration deadline, and the supplier needs to assess the risk of that use.

  • 31 May 2012 for 2013 registration, for quantities at or above 100 tonnes per year
  • 31 May 2017 for 2018 registration, for quantities at or above one tonne per year

This is a voluntary action.


 

Inform supplier of a use not covered in the safety data sheet of registered substance

Suppliers need to comply with their obligations before the next supply. However, if the next supply is within one month of receiving the downstream user request, suppliers have one month to comply.

Downstream users need to ensure full details are provided.

This is an optional action, based on the downstream user review of the safety data sheet.


 

Implement the measures communicated in the safety data sheet or take alternative actions

Downstream users need to implement the conditions of use within twelve months of receipt of the safety data sheet for a registered substance.

Alternatively, downstream users can take other actions:

  • Prepare a downstream user chemical safety report
  • Determine whether exemptions to preparing a chemical safety report apply
  • Change supplier, if feasible
  • Stop using the substance or substitute it

 

Communicate information to suppliers

Downstream users need to inform suppliers if the suggested risk management measures are inappropriate and whenever new information on hazards becomes available.

This obligation is laid down in Article 34 of REACH. If it is necessary, this should be undertaken without delay.


 

Communicate information regarding safe use to own customers

Downstream users have to communicate information regarding the safe use of their own customers within twelve months of receipt of the safety data sheet for a registered substance.

Downstream users need to update the safety data sheet without delay if:

  • New information on risk management measures or hazards becomes available
  • An authorisation was granted or refused
  • A restriction has been imposed

This obligation is laid down in Article 31(9) of REACH. 


 

Preparing a downstream user chemical safety report 

If downstream users need to prepare a downstream user chemical safety report, this has to be done within twelve months of receipt of the safety data sheet for a registered substance. They have to inform ECHA that they intend preparing a chemical safety report within six months.

However, downstream users do not submit the chemical safety report themselves to ECHA.


 

Downstream user report to ECHA    

Downstream users need to report unsupported uses to ECHA within six months of receipt of the safety data sheet for a registered substance.

This requirement applies if:

  • They prepare a downstream user chemical safety report.
  • They claim exemptions due to the use of a substance or mixture in a quantity of less than one tonne per year, or they use the substance for process oriented research and development (PPORD).
  • They have a different classification of a substance to their supplier.

There is one exception to this requirement. Downstream users do no need to report to ECHA if the quantity of the substance for that particular use is less than one tonne. However, the chemical safety report must still be prepared, if the total use by the downstream user is greater than one tonne per year.

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