Your role is that of a Downstream User
You are not obliged to register the substance/s that you use but if the substance is not registered that substance will no longer be available in the EU; if it is not registered for your use, you may need to change the way that you use the substance, the measures that you use to control risks, seek an alternative supplier or prepare a downstream user chemical safety assessment.
| For the substances which you use, you have the following rights: | |
Substance information exchange forum (SIEF) |
to join the SEIF for your substance but unlike manufacturers and importers you are not obliged to do so. Such a choice will, in turn, place data sharing obligations upon you. Specifically; SIEF participants shall provide other participants with existing studies, react to requests by other participants for information, collectively identify needs for further studies and arrange for them to be carried out (Article 29.3) |
Chemical safety assessment |
to request that your supplier to include your use in their chemical safety assessment. However, he is not obliged to do this if he considers that your use is not safe |
For the substances which you use, you have the following obligations: |
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Risk Reduction |
(a) to implement any appropriate risk reduction measures recommended by your suppliers; and (b) to abide by any use conditions for authorisation substances (where your use is outside the scope of the exposure scenario/s for that substance or outside of the conditions set in any authorisation you are further obliged to conduct a risk assessment covering your uses) |
Data sharing |
See SIEF obligations above |
Data retention |
to assemble and keep available for inspection all information relating to carrying out your duties under REACH for at least 10 years after you last manufactured a substance or preparation |
Communication
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to communicate relevant exposure information to users further downstream from yourself, including via safety data sheets |
| to provide your customers with information to enable them to use your preparation safely | |
| to report the information, set out in Article 38(2), to the European Chemicals Agency, before commencing or continuing with a particular use of a substance that has been registered by an actor up the supply chain in accordance, in the following cases: (a) the downstream user has to prepare a chemical safety report; or (b) the downstream user is relying on the exemptions to the requirement to prepare a chemical safety report |
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| to consider requests from users downstream of yourself for you to communicate their information to actors above you in the supply chain. You are not obliged to agree to their request | |
Contracting to or from third parties |
Sub-contractors performing the role of downstream users under REACH must comply with the downstream user obligations |
Manufacturers of preparations |
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Chemicals reactions take place following mixing of your preparation |
If a chemical reaction (dissolving and solvation are not considered chemical reactions) takes place following your mixing of substances and/or preparations, and a new substance is formed, your role is that of a manufacturer of that substance |
Manufacturers of articles |
You may have the obligations of a manufacturer in addition to those of a downstream user |
Storage Provider |
So long as you do not own the substances and/or preparations or perform any activities or operations with them (for example, you do not decant or re-label), then you have no obligations under REACH |
Distributers |
Your obligations are those of a distributor and are described seperately |
Retailers |
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