Downstream User Report

 Downstream user's use in relation to supplier's safety data sheet

When you receive an extended safety data sheet with exposure scenarios for registered substances you need to:

  • Check whether the exposure scenarios cover your uses

  • Check whether the conditions of safe use correspond to the conditions under which you use the substance

If there is a mismatch between your uses and the conditions of your use compared to those described in the extended safety data sheet provided by your supplier, you have various options.

You may either:

  • Ask your supplier to include your use in the chemical safety report and provide you with the relevant information on uses and conditions of safe use;

  • Adapt your own activities so that they match the conditions of safe use as determined by your supplier, or even discontinue the use;

  • Substitute the substance in question with a less hazardous substance

  • Look for another supplier of the same substance who provides the substance with an exposure scenario that covers the use; or

  • Produce your own chemical safety report.

If you choose the last option you need to report your use to ECHA.

Reporting a downstream user's use to ECHA

You have to report to ECHA when your uses are not included in the registrant's exposure scenarios and you need to prepare a downstream user chemical safety report.

Even if you don't need to prepare a downstream user chemical safety report, you still need to report your uses to ECHA if you use a total of less than one tonne per year for all uses of the substance or mixture or you use the substance for product and process-oriented research.

If you use the substance for more than one use, some exceptions may apply. Please refer to the fact sheet  for further information.

The report shall include:

  • The identity and contact details of the downstream user;

  • The identity of the manufacturer or importer or other supplier;

  • The registration number(s), if available;

  • The identity of the substance;

  • A brief general description of the downstream user's use and conditions of use; and

  • A proposal for tests if you consider that testing on vertebrate animals is necessary to complete the downstream user chemical safety assessment, and you use the substance in a total quantity of 1 tonne or more per year.

Currently the downstream user report must be submitted by compiling a dossier in IUCLID and submitting it via REACH-IT. ECHA is working towards making on-line reporting via REACH-IT possible.

The timelines

Your deadlines start from the day you receive an extended safety data sheet with a registration number.

If your uses are covered and you do not have to prepare your own chemical safety report, you have

  • 12 months to implement the measures communicated to you in the extended safety data sheet and to update the safety data sheets for mixtures you supply further downstream

If your uses are not covered you have

  • 6 months to report to ECHA

  • 12 months to carry out your own chemical safety assessment and to implement the related exposure scenarios.

See also