Downstream users are users of chemicals under REACH and CLP.  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, they should report this to ECHA within six months of receiving the eSDS.

For unsupported uses the current ECHA guidance states:

You have to report to ECHA within 6 months of receipt of the safety data sheet for a registered substance when you:

  • Need to prepare a downstream user chemical safety report; or
  • Wish to benefit from the exemption to prepare a chemical safety report either because:
  • you use the substance in total less than 1 tonne per year; or
  • You use the substance for product and process oriented research.

Classification differences

Downstream users must also report to ECHA if their classification of a substance differs from that of all of their suppliers. Reporting is not required if the downstream user uses the substance or mixture in a total quantity of less than one tonne per year.

Authorise uses

Downstream users that use a substance included in the Authorisation List, for which an authorisation has been granted that covers their use, have to notify ECHA of their use within three months of the first supply of the substance.

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