A downstream user is a company that uses a substance in its own activity (not a manufacturer or importer). Although there is no direct registration obligation, downstream users have important responsibilities.
Key obligations: confirming that the substances used have been registered by suppliers; complying with the conditions of use and risk management measures in the Safety Data Sheet; checking whether their use is covered by the exposure scenario; and, if not, informing the supplier or making their own assessment.
When a foreign manufacturer appoints an Only Representative, importers become downstream users. ONAY Mühendislik performs downstream user compliance analysis.
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Contact ONAY Mühendislik for KKDIK and REACH compliance support.
Yönetmeliğin resmî tam metni: KKDİK Yönetmeliği — Resmî Gazete.
Downstream users do not register
A downstream user uses a substance in its own process and does not file a registration. The obligation is different: to confirm that its actual conditions of use fall inside the exposure scenarios received with the safety data sheet, and to keep that check on file.
What to do when the use is not covered
Two routes exist. Ask the supplier to add the use to its scenario, or prepare your own downstream user chemical safety assessment. Doing neither leaves a gap that an inspector will find, because the registration then does not describe what your site actually does.
Practical record keeping
Keep the received scenario, the comparison with your real operating conditions and any correspondence with the supplier in one dated file. This is usually the first document requested during a chemical inspection and it takes minutes to produce when it has been maintained.
Extended safety data sheets
When a substance has a chemical safety report, the exposure scenarios are attached to the safety data sheet as an annex. Downstream users work from that annex, so the values in it and in the main text must agree. Conflicts between the two are treated as an unreliable file.
Communicating upstream
If your use is missing, tell the supplier in writing and describe the real operating conditions: duration, frequency, temperature, quantity and the controls in place. Vague requests produce vague scenarios, which is how the same gap reappears the following year.