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Downstream User |
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A downstream user means any natural or legal person other than the manufacturer or the importer, who uses a substance, either on its own or in a preparation, in the course of his industrial or professional activities. A distributor or a consumer is not a downstream user.
A preparation is a mixture or solution composed of two or more substances.
Downstream users will be manufacturers of inks, varnishes, coatings,
thinners, cleaners, photostencil emulsions, fixer, developer and
ink-filled digital cartridges.
A downstream user will sell to any European Union (EU) country or sell
to other downstream users who export to the EU or sell products to
manufacturers of articles that contain certain hazardous substances
sold in the EU.
A downstream user or may provide information to assist in the
preparation of a registration. A downstream user of a substance on its
own or in a preparation shall prepare a chemical safety report in
accordance with Annex XII for any use outside the conditions described
in an exposure scenario or if appropriate a use and exposure category
communicated to him in a safety data sheet or for any use his supplier
advises against.
What other actions are required by a downstream user? Inform customers
of the risk management measures. The risk management measures will
include the provision of control measures such as extraction, use of
personal protective equipment, proper waste disposal etc.
A downstream user shall report to the Agency if his classification or
usage of a substance is different to that of his supplier. This is
known as a “postcard registration.” A “postcard declaration” requires
the generation of a technical dossier and Chemical Safety Assessment by
the downstream user as opposed to the manufacturer undertaking the role.
For further information
REACH Regulation:
http://eur-lex.europa.eu/JOMonth.do?year=2006&month=12 reference L396
http://eur-lex.europa.eu/JOMonth.do?year=2007&month=5 reference L136
Questions and Answers on REACH:
 http://ec.europa.eu/environment/chemicals/pdf/qa.pdf
Guidance:
http://reach.jrc.it/guidance_en.htm
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