Substances with uses not registered under REACH
REACH involved the registration of uses for each substance, as well as the registration of the substance itself. This means that sometimes, for hazardous products, certain uses are not registered.
Also, as information comes to light through the REACH process, it becomes apparent that certain uses would expose people to dangerous levels of a substance, so uses which had been registered can be withdrawn.
An example of this is styrene, which has been used in two-part adhesives for consumer use, but which has had consumer uses withdrawn on the basis of the REACH exposure scenario calculations demonstrating that a safe level of use cannot be guaranteed for consumers.
In effect, this is a form of restriction, without taking a substance through the full formal process, and it relies on industry policing itself to a certain extent, although an inspection by the local Competent Authority should pick up breaches when comparing a supplier SDS with how a substance is handled on site.
Supplying a product which has uses which are not registered for REACH
In order to protect your business, when supplying a product which has uses which have not been registered, it may be sensible to include information on the uses not registered in the SDS.
You may also want to place a warning on the label, e.g. professional use only, or not for consumer use, or not to be used for (uses).
Receiving a REACH-registered product which you want to use (or sell) for a non-registered use
In this situation, you have a number of options:
- let your supplier know about your use, and ask them to include it in their registration
- find a supplier who is covering your use in their registration, or who is importing or manufacturing at sub-REACH levels (less than 1 tonne per annum)
- implement the conditions of use in the exposure scenario
- substitute the substance with another one
- prepare a downstream user chemical safety report (DU CSR) (check first if any
exemptions apply, see chapter 4.4.2).
For more information on preparing a downstream user chemical safety report, check for any exemptions in the Downstream User guidance, chapter 4.4.2, https://echa.europa.eu/documents/10162/23036412/du_en.pdf/9ac65ab5-e86c-405f-a44a-190ff4c36489 . If you need to prepare a CSR, see https://echa.europa.eu/view-article/-/journal_content/title/how-to-prepare-a-downstream-user-chemical-safety-report .