The overall position maintained by the Downstream Users of Chemicals Co-ordination group includes the following common elements. In particular, DUCC:

1. Welcomes the policy to base chemicals control decisions o­n risk assessments.
2. Calls for consideration of international risk assessment concepts.
   
3. Calls for efforts to be made to avoid duplication of legislation in the areas of health, environment and product safety.
   
4. Stresses the importance of good communication flows between producers and users of chemicals.
   
5. Considers communication to the public should be risk orientated rather than hazard o­nly.
   
6. Encourages the explicit possibility of its members being able to actively engage at all stages of REACH.
   
7. Emphasises the necessity to take the specific needs of Small and Medium-sized Enterprises (SMEs) into account.

A number of concrete proposals have been issued by DUCC.
These include:

• Support for a pre-registration step and exposure-driven, tiered risk assessment approach as promoted by ECETOC (Centre for Ecotoxicology and Toxicology of Chemicals) and as illustrated by the HERA (Human and Environmental Risk Assessment) model.
• The necessity to carry out risk assessments ahead of any decisions o­n restriction or authorisation and support labelling based o­n the likelihood of injury for consumer products as is offered by the Global Harmonisation System (GHS) for classification of chemicals.
  
• Encouraging centralised decisions through the creation of a European Chemicals Agency.