About downstream users

About downstream users

About downstream users

who is downstream user?

Downstream users are users of chemicals  under REACH and CLP. They are companies or individuals:

  • within the European Union/European Economic Area,
  • who use a substance, either on its own or in a mixture,
  • in their industrial or professional activities.


Examples include:

  • Formulators: produce mixtures, which are usually supplied further downstream. For example, paints, adhesives and cleaning agents.
  • End users: use substances or mixtures but do not supply them further downstream. Examples include users of adhesives, coatings and inks, lubricants, cleaning agents, solvents and chemical reagents like bleaching products. This includes producers of articles.
  • Producers of articles: incorporate substances or mixtures into or onto materials to form an article. Examples include textiles, industrial equipment, household appliances and vehicles (both components and finished goods).
  • Re-fillers: transfer substances or mixtures from one container to another, generally in the course of repackaging or rebranding.
  • Re-importers: import a substance, on its own or in a mixture, which has originally been produced in the EU, and registered by someone in the same supply chain.
  • Importer with an "only representative": importers are downstream users when their non-Community supplier has nominated an "only representative" for the purpose of acting as a registrant established in the Community.

Distributors who only store and distribute the chemical are not downstream users but they do have obligations regarding information flow within the supply chain. If, for example, they come in contact with the chemical by transferring or diluting it, they are downstream users. Consumers who use chemicals are not downstream users. 


Terminology related to downstream users

Downstream users work in a wide range of sites and setting and specific terms are used to describe the work environment. When the use takes place in a factory or other industrial site, this is termed as "use at industrial sites". When the downstream use takes place outside industrial sites (such as construction sites, office blocks, craft workshops) the term "widespread use by professional workers" is applied.
Environmental health and safety (EHS) management practices among end-users are described using the terms "advanced" and" basic". Advanced practices are associated with training of workers, proper work instructions, supervision and regular cleaning and maintenance. The terms "industrial setting" and "professional setting" have also been used to reflect advanced and basic EHS management practices respectively.
For example, the type of site for spray painting a car in a dedicated automotive workshop is "widespread use by professional workers". If the EHS management is at a high level, this is described as "advanced" or "industrial "setting".