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Downstream users: Your obligations regarding REACH regulation
You have some new obligations under REACH related to the safe use of chemicals, communication, reporting and keeping and up-dating information.
You also have the option of playing a pro-active role.
Your main tasks are:
- To have an overview of substances you work with
- To have an overview of your customers
- To list your suppliers and make chemicals uses known to them
- To warn customers and suppliers on REACH and future needs (pro-active role)
- To have answers to basic issues:
a.Will substances, preparations or articles (1) I use and/or used by my clients be submitted for registration by my suppliers (or another supplier)?
b.How will I manage upstream impacts, such as suppression of substances and suppliers, higher prices of raw materials, necessary substance reformulation…?
- To identify and apply measures to control risks, to collect exposure information (communicated in suppliers SDS)
Do you receive SDS?
No: you have only very limited obligations under REACH
Yes: you have to apply the risk management measures identified in the SDS
- To communicate up in supply chain (new information on hazardous properties)
- To communicate to customers (to ensure that risks are controlled)
- To report to the Agency (if > 1 ton per annum)
- To report to authorities
- To keep and update information (general obligation for all actors to keep information available for at least 10 years)
(1) Especially in case of substances that are intended to be released or submitted to authorization (CMR…)
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