If you are a downstream user, you need to analyse the origin of your products. Your supplier could be in the EU, but if he is not, you are probably the importer of the product and its component substances, with the concomitant obligations to register. An important feature for a downstream user is to ensure the continuity of supply.
- Will your suppliers register all substances you need to stay in business?
- Have you already identified your key substances?
- Do you have alternative suppliers, substitutes for your raw materials or
- can you adapt your processes in case your supplier chooses not to register your key substance?
The performance of a chemical safety assessment is an obligation of your supplier, but you need to tell him how you use his product in your process for him to be able to develop the exposure scenarios.
- Do you want to tell him, or
- will you do your part of the safety assessment by yourself?
In many cases the branch organisations are a channel for this type of communication but they need to be mobilised, too.