D
Downstream User
Definition
Under REACH Article 3(13), a downstream user (DU) is any natural or legal person established in the EU, other than the manufacturer or importer, who uses a substance, either on its own or in a mixture, in the course of their industrial or professional activities. Downstream users include formulators, processors, and industrial users. They are distinct from distributors. Downstream users have specific REACH obligations including: checking eSDS coverage, preparing downstream user CSRs where required, notifying ECHA of uncovered uses under Article 38, and applying appropriate risk management measures.
Source
REACH Regulation (EC) No 1907/2006, Article 3(13), Article 37, Article 38.
Practical Explanation (Compliance Context)
Downstream users must identify all their uses of substances and verify that each use is described and covered in the supplier’s eSDS exposure scenarios. Uncovered uses must be addressed by one of four routes: notify the registrant; use a third-party DU described use; apply for own authorisation; or discontinue the use. Article 38 requires DUs to notify ECHA of uses not covered by the supplier’s CSR if certain conditions are met.