DUCC publishes tips for dowsntream users on substance evaluation
DUCC members have expressed some concerns about the lack of involvement of downstream users in the substance evaluation process.
According to the legal text, DU can contribute to this process, as they may be in possession of information useful for substance evaluation, such as use and risk assessment data, sometimes measured data. However, as DU are not known to the evaluators and are not present in the SIEF/consortia, there is no process to make sure DU sectors/companies can take part to this preparation and provide complementary data. Indeed, if additional information on exposure is sought by the Lead Registrant only in the 30-day period to comment on the initial draft decision (as we have seen happening), this is too short to provide impactful information and to assess together the most appropriate response.
ECHA’s leaflet, “Substance evaluation under REACH - Tips for Registrants and downstream users”, strongly advises that registrants and DUs prepare together, as early as possible, the participation in the evaluation process of the listed substances, but the experience of several of our members shows that this is rarely the case in practice.
Anticipation is of utmost importance, since DUs may be deeply impacted by the outcome of these decisions. In many cases, DUs can be even more impacted than M/I since they also have to comply with other legislations, e.g. for paints, detergents, cosmetics, toys, food-contact, RoHS, etc., and the decisions may entail re-formulation of products.
DUCC acknowledges and welcomes the fact that ECHA publishes already:
- the contact details for the Member State competent authority responsible for the evaluation of each substance, so that companies or trade associations can provide their input directly;
- the list of nominated Lead Registrants (when agreed by the LR), so that companies can check for the identity of the LR once a critical substance is listed in the (draft) CoRAP list
DUCC publishes this document with Tips for Downstream Users, providing clear instructions based on the existing possibilities for our members and DUs in general to be informed about which substances may go under substance evaluation.