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Other issues affecting downstream users

Other issues affecting downstream users

Regulatory control

Downstream users have responsibilities when a substance they handle is subject to regulatory risk management such as authorisation, restriction or harmonised classification. The main requirements are summarised below.


If downstream users use a substance that is on the Authorisation List, they should try to substitute it with a safer alternative. If they want to continue to use the substance, the downstream users or their supplier need to apply for an authorisation for that use, and additional obligations apply.

This decision needs to be made as soon as the substance is included in the Authorisation List as the processing of the authorisation application takes time.

Downstream users that use a substance included in the Authorisation List, for which an authorisation has been granted that covers their use, have to notify ECHA of their use within three months of the first supply of the substance.

If a substance is subject to authorisation, the supplier must communicate this in Section 15 of the safety data sheet (SDS) or in the other information supplied in line with Article 32 of REACH. The authorisation number must also be included on the label.


If a restriction applies to a substance that downstream users use, they may only continue to use it if they comply with the conditions of the restriction. Any EEA suppliers must include information on whether a substance they supply is subject to a restriction in Section 15 of the safety data sheet or in other information supplied in accordance with Article 32 of REACH.

Harmonised classification

For some substances, the classification is agreed by independent experts at European level. This is called harmonised classification. When a substance has a harmonised classification, suppliers and downstream users must use that classification.

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