ECHA Urges Downstream Users of Chemicals to Give REACH-Required Information to Suppliers

October 13, 2009 // Published as a news service by IHS

ECHA urged such users to comply soon, but noted that the upcoming deadline, Nov. 30, 2009, applies only if the substance needs to be registered before Dec. 1, 2010.

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Under REACH, if you are a Downstream User of a chemical, you should inform your suppliers about your use of a substance if you want the supplier to consider your use in relation to its registration.

Before informing your supplier, you are advised to check the use mappings prepared by your industry association, as well as any communication from your supplier about the uses it intends to cover. Alternatively, you can assess the use later and fulfill the related duties yourself.

The advantage of communicating your use in time to your supplier is that your conditions of use are then more likely to be covered by your supplier's Exposure Scenario, as the registrant of the substance will have to take account of your use in preparing the Chemical Safety Assessment.

You can then expect your use to be an identified use and have an Exposure Scenario covering your conditions of use, unless the registrant cannot support the use. If the registrant cannot support your use for reasons of protection of human health or the environment, both the Downstream User and the ECHA need to be notified.

If you do not communicate your use and it is not covered by your supplier's Exposure Scenarios, you will eventually need to prepare a Chemical Safety Assessment yourself once the substance has been registered.

You need to provide your information in writing to your supplier on both the use and the conditions under which the substance is used.

ECHA has published a fact sheet that provides background information and further details about the Downstream Users' right to inform their suppliers of the use they make of the substance, as listed below. In addition, there is REACH guidance available, and tools have been developed by industry to help you. Your industry association may also be able to assist.

Further Information
For more information, see:

• REACH Guidance for Downstream Users (chapters 4, 6, 7 and 8):
• Guidance on Information Requirements and Chemical Safety Assessment, Chapter R.12: Use Descriptor System
• Downstream Users - How To Make Uses Known To suppliers (REACH fact sheet)

In addition, the following industry guidance and tools are available (although ECHA does not endorse tools or guidance developed by industry, and recommends you contact the relevant industry association for further information about these tools):

• The Libraries section of the European Chemical Industry Council (Cefic) web site contains an overview of Downstream Users' use mapping activities, which can be consulted at http://cefic.be/en/reach-for-industries-libraries.html.
• The Downstream Users of Chemicals Coordination (DUCC) group provides links to the Downstream Users' tables of uses at http://www.duccplatform.org/activities/use_and_exposure_info.html.
• Guidance on managing use communication in the supply chain developed by Cefic can be consulted at http://cefic.be/Files/Publications/Guidance_Use_and_ES_dvlpt_and_SCCm.doc and http://cefic.be/templates/shwPublications.asp?HID=750&T=806.
• The Downstream Users of Chemicals Coordination group's member associations are
  using the DUCC template for describing uses and providing basic Operational Conditions/Risk Management Measures. They have worked with Cefic to ensure respective templates are complementary. The DUCC User template (empty) can be found on the DUCC web site.

Source: European Chemicals Agency (ECHA).