Skip to Content
Skip to Content

More on downstream user responsibilities

More on downstream user responsibilities

Unsupported uses

downstream user report

(REACH Article 38(1)) Downstream users have to report unsupported uses (outside the conditions described in the exposure scenario provided by the supplier) to ECHA within six months of receipt of the safety data sheet for a registered substance if:

  • They prepare a downstream user chemical safety report (DU CSR) and the particular use is more than one tonne per year. 
  • They are exempt from preparing a DU CSR because they use less than one tonne per year of the substance or mixture in total.
  • They are exempt from preparing a DU CSR because they use the substance for product and process oriented research and development (PPORD).

The report includes a brief general description of the downstream user's use and conditions of use. It should also include a proposal for tests if testing on vertebrate animals is considered necessary.

Classification differences

(REACH Article 38(4)) Downstream users must report to ECHA  if their classification of a substance differs from that of all of their suppliers. Reporting is required within six months of receipt of the safety data sheet for a registered substance.

Reporting to ECHA is not required if the downstream user uses the substance or mixture in a total quantity of less than one tonne per year, as outlined in Article 38(5).

Authorised uses

(REACH Article 66) 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.

Categories Display

Tagged as:

(click the tag to search for relevant content)


Route: .live2