REACH: Less Than Two Months Left To Deadline For Users Of Chemicals To Inform Suppliers
There are less than two months left for the Downstream Users of chemical substances to inform their suppliers of the use they make of the substance. The deadline, 30 November 2009, applies only if the substance needs to be registered before 1 December 2010.
As a user of a chemical (Downstream User) you should inform your suppliers about your use of a substance if you want the supplier to consider your use in relation to his registration. Before informing your supplier, you are advised to check the use mappings prepared by your industry association, and/or any communication from your supplier about the uses he intends to cover. Alternatively, you can assess later the use and fulfil the related duties yourself.
The advantage of communicating your use in time to your supplier is that your conditions of use are then more likely to be covered by your supplier’s Exposure Scenario, as the registrant of the substance will have to take account of your use in preparing the Chemical Safety Assessment. You then can expect your use to be an identified use and have an Exposure Scenario covering your conditions of use, unless the registrant cannot support the use. If the registrant cannot support your use for reasons of protection of human health or the environment, both the Downstream User and the European Chemicals Agency need to be notified.
If you do not communicate your use and it is not covered by your supplier’s Exposure Scenarios, you will eventually need to prepare a Chemical Safety Assessment yourself once the substance has been registered.
You need to provide your information in writing to your supplier on both the use and the conditions under which the substance is used.
ECHA has published a Fact Sheet that provides background information and further details about the Downstream Users’ right to inform their suppliers of the use they make of the substance. In addition, there is REACH guidance available, and tools have been developed by industry to help you. Your industry association may also be able to assist.
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