We offer a comprehensive service for downstream users with regard to all obligations that REACH burdens on them.
Downstream users may view supplier registration(s) as the answer to all their REACH obligations. In reality this is not the case. Title V of REACH deals exclusively with downstream users, imposing two significant obligations.
They must operate within the scope of a chemical safety assessment (CSA) that has been either prepared by themselves or the registered supplier (art. 37). Secondyl, they must report information to ECHA under certain circumstances (art. 38).
Additionally, the downstream user may have further REACH obligations under:
- art. 31 – requirements for the SDS;
- art. 32 – communication of information down the supply chain (SDS not required);
- art. 33 – communication of information on substances in articles;
- art. 34 – communication of information on substances and mixtures up the supply chain;
- art. 35 – workers’ access to information;