REACH Update: Downstream User Obligations, Identified Uses and Use Descriptors

By: Annelie Struessmann, PhD, CONUSBAT

Posted: September 22, 2009

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The option of making a use known to the supplier is established in Article 37, where the DU’s duty to identify, apply and recommend risk reduction measures is described. The DU must provide sufficient information or (if appropriate) a use and exposure category (UEC) to the supplier preparing an ES for addition to the chemical safety assessment. For more information on exposure assessment elements, read the August REACH Update.

When a DU prepares the chemical safety report, the ECHA must be notified before the DU can commence or continue using a substance that has been registered by an actor up the supply chain (Article 38).

REACH relies upon communication along the supply chain. According to Title IV, all information regarding substance properties must be passed down the supply chain. While DUs producing preparations generally are required to share all the relevant information they receive from various suppliers for each substance used, such information requirements do not apply to cosmetic products since they are exempt [Title IV-Article 2 (5b)].

To assist suppliers and DUs in structuring their communication and to facilitate standardization of ESs, the ECHA recommends a use descriptor system² including standardizing short titles to describe a given use. Based on this descriptor system, a DU can quickly establish whether an ES received with an eSDS covers its use(s) of the substance. Several European trade associations have mapped use descriptors for their member industries. For cosmetic product use-mapping, visit the Colipa Web site.

Do you have additional questions? Visit C&T magazine's REACH RoundTable.