Under REACH, Downstream Users (DU) should not place o­n the market substances as such, in preparations or in articles if they have not been duly registered by the relevant manufacturers or importers (unless they are specifically exempted from registration).
For many substances, a chemical safety report will have to be submitted as part of the registration dossier: exposure scenarios covering the various identified uses will have to be generated and communicated to downstream users via safety data sheets, as applicable.

REACH gives downstream users the right to communicate their uses, together with specific conditions of use, to their suppliers with a view to make their use an identified use covered in the registration dossier. Distributors should pass o­n the information in the supply chain. However, REACH does not prescribe any particular format for exchanging information o­n uses in the supply chain.
Standard processes and tools are necessary to facilitate use communication, exposure scenario development and guarantee that registration dossiers adequately address all (or as many as possible) uses of substances.

Communication of uses
To avoid that multiple and inconsistent formats be used by different companies or different DU industry sectors for their use inventories and reporting, DUCC developed the UseR (Use Reporting) template to assist downstream users in informing their suppliers o­n their uses and conditions of use, thereby assisting o­n the preparation of registration dossiers.
This template is a tool that DU associations and their members can use for mapping and reporting uses for their respective sectors.

It contains two tables:

• o­ne table for description of uses: this should be done following the Use Descriptor System developed by ECHA.
• o­ne table that, in addition to use descriptors, contains typical basic operational conditions and risk management measures. This additional information is provided to allow exposure assessment at screening level or “Tier-1” level using the ECETOC Targeted Risk Assessment tool (a standard exposure assessment tool under REACH). It has deliberately been kept simple.

Each Downstream User Association is responsible for filling and updating the use information for its sector and post the corresponding tables or inventories o­n their respective website, so that they are readily accessible by registrants.

NEW (March 2012) - DUCC, Cefic and Fecc have agreed to advise their members to follow the "top-down approach" regarding the use communication for preparing 2013 registrations. For more information please see the Letter and the Fact Sheet o­n use communication.

NEW (February 2012) - based o­n experience gained with 2010 registrations, UseR template has been revised. A column has been added to the operational conditions table, which allows each company to indicate the concentration of the substance in the mixture, if considered relevant. This is a parameter that may be important when registrants are performing their chemical safety assessment, in the sense that it allows a more adequate estimation of the exposure.

Links to the DUCC member associations’ websites posting use and exposure information:
 
Cosmetics | Detergents and cleaning products | Paint, printing ink and artists’ colours | Construction chemicals | Photographic materials and imaging | Chemical distributors | Adhesives and sealants

Safety Data Sheets
Manufacturers, importers, downstream users and distributors are already today required to compile and supply a Safety Data Sheet (SDS) at the first delivery of a dangerous substance or preparation.
REACH takes over this existing duty in its Article 31 (requirements for the Safety Data Sheets) and in Annex II (guide to the compilation of Safety Data Sheets).
Safety data sheets will continue to contain information o­n the hazards of the substance or the preparation, as well as information o­n the recommended risk management measures to adequately control any risks to health and environment.
In addition, for all those substances for which a chemical safety assessment (CSA) is required and that are classified as hazardous, the relevant exposure scenarios shall be annexed to the Safety Data Sheets (SDS).
This obligation to annex exposure scenarios to the SDS has to be fulfilled by:

• Downstream users: For substances supplied to them, classified as hazardous, that they place o­n the market (and that are manufactured or imported in quantities above 10 T/year), and where applicable and where relevant for preparations they place o­n the market.
• Distributors: if they have received such information and it is relevant for their customers.

Guidance and Tools
DUCC and its member associations are involved in the development of industry practical guidance, including guidance o­n safety data sheets for mixtures, assessing methodologies to combine and integrate information contained in exposure scenarios of individual substances into safety data sheets of mixtures.

• Standard letter about ESCOM to be sent by companies to their IT Providers
  This document has been prepared by DUCC in order its members can inform their IT Providers about the existence of ESCOM. 
  
  
• Messages to communicate in the supply chain o­n extended SDS for substances II (13 July 2011)
  This document has been jointly prepared by Cefic, Concawe, FECC and DUCC.
  It provides answers to some of the most frequently asked questions regarding the communication of extended SDS in the supply chain.
  It also includes a check-list for those receiving an extended SDS.
  
  
• Guidance for managing the revision of SDS for mixtures and communicating those under REACH and CLP (30 March 2011)
  
  
• ESCom Standard
  A catalogue with standard phrases for Exposure Scenario communication has been prepared by different industry sectors, associations and companies. IT providers together with industry have also developed an XML standard for communication between different IT systems.
  The download package now contains also an XML standard, prepared by ECHA, for ESCom phrases import in Chesar 1.2.
  The use of the harmonised phrase catalogue together with the XML standard by all stakeholder of the Exposure Scenario communication process is essential. The complete package, called ESCom, together with the ESCom phrases import in Chesar 1.2 XML standard, is available for free after registration and acceptance of the license conditions.
  
  
• Exposure assessment using the BAMA/FEA Indoor Air Model
  The REACH Regulation and the Aerosol Dispensers Directive (ADD) both require that all chemicals are used in aerosol in a way that does not adversely affect human health. The BAMA/FEA Indoor Air Model is a simple but powerful tool, independently validated by experts from BRE (UK) who concluded that the Model 'can be used to predict the concentration of aerosol components within a room after a suitable time interval after spraying'.
  The tool is available for free.

Note: each company remains individually responsible for compliance with REACH.

For more information o­n supply chain communication, use identification and exposure scenarios, visit the following websites:

• ECHA's Guidance website
• ECHA Guidance o­n the compilation of SDS (final version September 2011)
• Guidance from industry o­n supply chain communication and exposure scenario development
• ECETOC targeted risk assessment tool for "Tier 1" exposure calculation
• Catalogue of standard phrases