User of chemicals
Most industries and even the smallest companies use chemicals. Hazardous chemicals are labelled to communicate the risks and help avoid accidents. Safety data sheets are also provided.
You may already be implementing good risk management practices, but are you aware of all your rights and responsibilities under the law? The more hazardous the substance or mixture you use, the more that is required from you and your supplier.
How do you use chemicals?
You may use chemicals in many ways:
- Blending them into new formulations and placing them on the market
- Producing articles (such as automotive tyres, paper, furniture, clothing)
- As part of a process (such as cleaning, dying, lubricating)
- In a service you provide (such as dry cleaning, car repair, construction, painting)
You have a clear role for advancing the safe use of chemicals which is defined in REACH and CLP as a downstream user.
You are a downstream user, if:
- You are established in the EEA, and
- The supplier of a substance or mixture you use is also established in the EEA, and
- You use chemicals in your industrial or professional activities, as described above
You are not a downstream user, whenever:
- The supplier of a substance you use is established outside the EEA and has not designated an only representative to register the substance and ensure its access on the EU market. If this is the case, you are an importer
- You only store chemicals and place them on the market (without changing their composition or packaging). Then you are a distributor
- You buy a product and you use it yourself outside an industrial/professional setting. If so, you are a consumer
What do I have to do?
Downstream users do not have the obligation to register, but they have to:
Using chemicals safely is a legal responsibility for all companies dealing with chemicals in their industrial and professional activities.
You need to comply with the REACH requirements regardless of your company size and your position in the supply chain. You must implement the operational conditions and risk management measures included in the safety data sheets provided by your supplier.
You must also inform your suppliers about how you use their chemicals, particularly if your uses are not covered in the information you receive, or the safety advice is not appropriate.
If you blend chemicals into mixtures and place them on the market, you have important responsibilities to ensure your customers can use the products safely.
You must communicate the relevant information on safe use to them. You also have to classify every mixture before you place it on the market. If it is hazardous, you have to label it so that workers and consumers know how to manage the risks.
Important changes have been in place from 1 June 2015 – the hazardous mixtures you place on the market must be classified, labelled and packaged according to the new CLP requirements.
By communicating effectively with your suppliers and customers, you can help to ensure that relevant information is provided throughout the supply chain.
Biocidal products are hazardous by their nature and can be harmful to humans, animals and the environment. Active substances are only approved for use by specific product types. Specific requirements apply for the labelling and packaging of biocidal products to ensure that they can be used safely.