Training for Downstream Users

W E D N E S D A Y, September 5, 2018 (09:00 – 13:00)

Learn how to meet REACH obligations as a downstream user.

The DU training seminar will focus on:

  1. in first instance explaining in some detail these DU obligations**,
  2. explain how the supportive tools can be of help for users,
  3. pratical on hands training by using the tools to get acquainted to them.

The training session will be provided by Frederik Verdock from ARCHE and Hugo Waeterschoot from Eurometaux, both experienced REACH risk assessors.

“DOWNSTREAM USERS” – are companies (industry or professionals) or individual workers who use chemicals. They include formulators or companies who manufacture goods or offer services where chemicals are not the main element of their business, such as food, construction or cleaning companies*. The chemicals used typically include paints, metals, adhesives, solvents and cleaning
agents (

While manufacturers develop and supply the main information to their direct users, downstream users (DU) have a key role to play in advancing the safe use of chemicals. They do this by implementing safe use at their own site(s) and communicating relevant information both to their suppliers and their customers. Upstream, downstream users have to communicate uses that were not covered by the
suppliers, data that could help the supplier to refine the (generic) exposure scenarios (e.g. operational conditions) and/or the availability of potential alternatives in case of substances on Annex XIV.
Downwards, they need to review the (generic) exposure scenario information received from the suppliers, scale it for the changes they make (e.g. mixtures), define the modified hazards and risks and communicate these to their supply chain including how to safely use these products. These tasks are complex and require skills and data downstream users do not necessary have about their (end)users.

*Downstream Users – examples:
Formulators: produce mixtures, which are usually supplied further downstream. For example, paints, adhesives and cleaning agents.
End users: use substances or mixtures but do not supply them further downstream. Examples include users of adhesives, coatings and inks, lubricants, cleaning agents, solvents and chemical reagents like bleaching products. This includes producers of articles.
Producers of articles: incorporate substances or mixtures into or onto materials to form an article.
Examples include textiles, industrial equipment, household appliances and vehicles (both components and finished goods).
Re-fillers: transfer substances or mixtures from one container to another, generally in the course of repackaging or rebranding.
Re-importers: import a substance, on its own or in a mixture, which has originally been produced in the EU, and registered by someone in the same supply chain.
Importer with an “only representative”: importers are downstream users when their non-Community
supplier has nominated an "only representative" for the purpose of acting as a registrant established in
the Community.

REACH Conference Bratislava 2018 Ekotox Centers
To help downstream users meeting their obligations, the metals sector developed several tools to facilitate compliance with REACH’s communication duties on safe use. Those include :

  • Supporting guidance for Downstream Users developed by Eurometaux to explain how to comply with the requirements set in the REACH Exposure Scenarios (ES). This guidance takes the DUs through the ES content step by step, helping assessing compliance with information reported in the Registration Dossiers, and providing simple decisional boxes to define compliance. Additionally it includes an extensive list of abbreviations & other relevant background documents
  • Exposure assessment tools to estimate the potential exposure levels of metals or inorganics in case relevant monitoring data are not available or not reliable:
    •  MEASE (Metals Exposure Assessment Scenario tool) for workplace purposes (version
    • SPERCs (Specific Exposure Release Concentrations) for environmental releases from
      manufacturing or users of metals
  • An Exposure assessment scaling tool to help adapting environmental Generic Exposure Scenarios to typical local/DUs conditions. This Excel sheet based on EUSES heps calculating DUs exposure and risks

All these tools are freely available from the Eurometaux REACH Metals Gateway website.
**Downstream Users Responsibilities:

  • Identify and apply appropriate measures in the safety data sheet and exposure scenario
    When downstream users receive a safety data sheet (SDS), they need to identify and apply appropriate measures to adequately control the risks. When it is an extended SDS, they must additionally check whether the exposure scenario covers their own use of the substance and their conditions of use or take alternative action.
    This must be done within 12 months of receiving an SDS for a registered substance. Downstream users need to report to ECHA within six months of receipt of the safety data sheet (SDS) for a registered substance if their use is not supported and they prepare a DU CSR or claim exemptions.
  • Inform suppliers if they have new information on the hazards or risks
    Downstream users need to inform suppliers if the recommended risk management measures are inappropriate and whenever new information on hazards becomes available. This responsibility is outlined in Article 34 of REACH and should be undertaken without delay.
    Downstream users are also entitled to provide information regarding their uses of a substance (or substance in a mixture) to suppliers of substances. This enables registrants to include these uses in their chemical safety assessments. See “REACH registration and downstream” for more information.
  • Comply with regulatory requirements for chemicals of concern
    Chemicals of concern may be subject to regulatory risk management such as authorisation, restriction or harmonised classification. Downstream users are advised to keep informed on the regulatory activity to make sure they are aware of their responsibilities that apply now or in the future. They are encouraged to engage in public consultation to provide information necessary for decision making by regulators.
  • Comply with requirements for articles containing substances of very high concern (SVHCs) on the Candidate List
    If downstream users produce or import an article containing a Candidate List SVHC in a concentration above 0.1 % (w/w), they must give sufficient information to allow recipients of the article to use it safely. The information should be provided on supply to downstream users and, if requested by consumers, within 45 days of receipt of the request.

REACH Conference Bratislava 2018 Ekotox Centers
In addition, if the Candidate List substance is present in those articles in quantities totalling over one tonne per producer or importer per year, the downstream user should notify ECHA within six months of inclusion in the Candidate List.
Substances intended to be released from an article in quantities totalling over one tonne per year during use may need to be registered.
Downstream Users Training will focus on:

  • How to determine yourobligations;
  • How to prepare for theimpact on your business;
  • Communication with suppliers and exposure scenarios received from suppliers;
  • Communication with customers;
  • Downstream users chemical safety report;
  • What approaches can be used to comply with the legal requirements.

Training will be provided in English only.
Free of charge participation for REACH Conference Attendees
= Full 2 days REACH Conference Fee paid
P r e f e r e n c e  f o r  r e g i s t r a t i o n  t o  t h e  DUs  T r a i n i n g a p p l i e s


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