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

By: Annelie Struessmann, PhD, CONUSBAT

Posted: September 22, 2009

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Key Summary:
• A DU must have a chemical safety report (CSR) prepared when using a substance classified as dangerous in total quantities exceeding one tonne/year.
• The CSR provisions apply to the DU when a supplier’s eSDS is received.
• The DU must verify that the supplier’s eSDS covers its own use(s) and specific operational conditions and risk management measures.
• If the DU’s use is not covered in an eSDS, the best follow-up approach must be decided on a case-by-case basis.
• The option of notifying a supplier of a new use includes the DU’s provision of providing sufficient information to allow the supplier to prepare an ES to add to its registration.
• Where a DU prepares a CSR on its own, the ECHA must be informed before that DU can commence or continue using the substance.
• All information on a substance's properties must be passed down the supply chain, except for cosmetic products, which are exempt from these provisions.
• In order to assist in communicating ES requirements, the ECHA recommends a use-descriptor system; i.e., standardized, short titles for given uses.
• Several European trade associations have mapped out use descriptors for their member industries. 

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