Downstream User Reports

Downstream users of chemicals (EU and UK)

Downstream users are those who use chemicals in the course of their industrial or professional activities. They can be companies or individuals.

Unsupported uses

When downstream users receive an extended Safety Data Sheet (eSDS), they should check whether the exposure scenario covers their own use of the substance.

If their use is not supported for a registered substance:

EU (REACH/CLP): The downstream user must report this to ECHA within six months of receiving the eSDS.
UK (UK REACH/CLP): The downstream user must report this to the Health and Safety Executive (HSE) within six months of receiving the eSDS.

Downstream users need to report unsupported uses if they:

Need to prepare a downstream user chemical safety report; or
Wish to benefit from an exemption from preparing a chemical safety report, for example:
- Using the substance in total less than one tonne per year; or
- Using the substance for product and process-oriented research (PPORD).

Classification differences

Downstream users must also report if their classification of a substance differs from that of all their suppliers:

EU: Report to ECHA.
UK: Report to HSE.

Reporting is not required if the total quantity used is less than one tonne per year.

Authorised uses

For substances included in the Authorisation List:

EU: If an authorisation has been granted covering their use, downstream users must notify ECHA within three months of first supply.
UK: If an authorisation has been granted covering their use, downstream users must notify HSE within three months of first supply.

Note: Businesses in Northern Ireland follow EU REACH and report to ECHA, while businesses in Great Britain (England, Scotland, and Wales) follow UK REACH and report to HSE.