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Other issues affecting downstream users

Other issues affecting downstream users

DU and Reach registration

If you rely on chemicals for your EU operations, you need to be aware of the registration status of the substances you use. The last registration deadline was on 31 May 2018 for substances manufactured in or imported into the EU/EEA between 1-100 tonnes per year per manufacturer or importer. 

Except in specific circumstances (e.g. annual tonnage less than 1 tonne), if your suppliers have not registered the substances they supply to you, they are not complying with REACH and can no longer legally supply those substances. You can protect your business from interrupted supply by:

1. Identifying critical substances for your business

  • Look at substances in your ingredients and process materials that are critical for your business. This also applies to substances in mixtures.

2. Checking the registration status of the substances and looking for alternative suppliers, if necessary 

  • For hazardous chemicals, the registration number should be on the safety data sheet in Section 1.1 for substances or Section 3.2 for substances in mixtures.
  • Registered substances are listed on ECHA's website. Check Q&A 399 - How can I check if my supplier has a valid registration? for more details on how to check their status.
  • Companies that have registered the substance can be found on ECHA's website. Check Q&A 1516 - How do I know whether or not a substance has been registered?  for more details on how search for such companies.
  • It is likely that a substance should be registered if your supplier manufactures or imports it in volumes more than one tonne per year. Certain types of substances are not subject to registration obligations, such as naturally occurring substances or substances subject to registration or licensing under other legislation, such as substances in food. If you have doubts, we suggest you contact your supplier to ask for clarifications.

3. Checking that your uses are covered in the registration, particularly if you use a substance in a novel way

  • A downstream user has to apply the measures described in the exposure scenario or take alternative actions. When you receive exposure scenarios, you need to check that your use is covered. You can find more information by navigating to the “More on downstream user responsibilities” web page and selecting “Checking your use”. Note that you have the right to inform your suppliers on your uses, so that registrants can cover the use in their registrations.
  • If you operate within an organised sector, your sector organisation may have generated use maps that describe typical uses and conditions of use in an agreed format that registrants can easily use. This saves time, as it is not necessary to contact your supplier directly. Check the use maps library on ECHA’s website to see whether your industry sector has provided such use maps.
  • If you have doubts, we suggest you contact your supplier to ask for clarifications.

4. If no supplier has registered the substance you really need, consider importing it directly 

  • If you import more than one tonne of a substance per year, you need to register it.
  • Registration requirements are less demanding for quantities below 10 tonnes per year.

 

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