Helpless Downstream Users?

The REACH-EN-FORCE II project starting summer 2011 will focus on the obligations of downstream users in REACH, and inspectors have attended special trainings.

But what are the exact obligations a downstream user has to fulfill and what are the timelines?

Many of them are not sure about their duties but also about their rights. Some companies have not informed their suppliers about their identified uses of substances that may have been registered meanwhile. They are now running the risk of not having their uses considered in the exposure scenarios of the Chemical Safety Reports and the Extended Safety Data Sheets.

These companies now need a solution or a proof for compliance with the requirements of art. 37 REACH.

Safety Data Sheets also will be a topic inspectors focus on. As industry had experienced difficulties with the implementation of the new format in time, CEFIC asked ECHA for more patience and a grace period. Nevertheless, the enforcement is carried out by national authorities who may strictly stick to the statutory provisions and timelines.