REACH “Users of substances & preparations”

Role of the “Downstream users”

According to REACH (art. 3.12), a downstream user is: “every natural or legal person with a seat in the Community which is not a producer or an importer, who uses a substance as such or in a preparation for industrial or professional activities.”

As a downstream user, you will need to verify that substances, either on their own or in preparations, will be registered for your use. Inform your supplier of your application so it can be considered an “identified use” and be included in the registration file as such. This does not happen automatically!

The information about risk control measures that you, as a downstream user, receive from Interflon, must be applied in your production process in order to guarantee the safe use of the substances/preparations.

The ordinance stipulates that downstream users are required:

• To comply with the instructions with respect to the safety of chemical substances as outlined by Interflon in the MSDS and to work in accordance with the recommended risk control measures in the MSDS.
• To pass the MSDS to all other users, to conduct a risk assessment for the workplace and to take risk control measures accordingly.
• In case the MSDS contains an exposure scenario for the use of a product, to introduce the prescribed risk control measures in the internal organisation.
• To store all data about a substance or preparation for no less than ten years and to make these available to the authorities in the Netherlands or to the ECHA on request.

Non-identified use

If the use of a substance/preparation that is supplied by Interflon deviates from the use as submitted upon the original registration (non-identified use), REACH stipulates that the “downstream users” will:

• Inform the local representative of Interflon in writing of the use, so as to make the use identified, or;
• draw up its own chemical safety report and bring this to the attention of the European Chemicals Agency (ECHA) (at a ton limit of 1 ton/year or more) and;
• draw up a Material Safety Data Sheet (MSDS) with identified uses. The MSDS must contain exposure scenarios, safety recommendations and measures and other relevant information concerning the proper use of a chemical substance.

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