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Dow and REACH - Use Communication 2013 Registrations


Directly after the successful completion of the substance registration for the REACH 2010 timeline, Dow started to prepare for the next registration deadline based on the experiences gained and the best practices identified.
During preparation for 2010 registrations it was our experience that the initial communication within the supply chain of uses following the top-down approach - i.e. from manufacturer/importer to downstream user - developed by industry associations, was the least burdensome on all actors in the supply chain. This approach is also advocated and supported by the main industry associations (Cefic, FECC, DUCC). With some modifications, Dow will use this approach again in preparation for the 2013 registrations. In short, this means that:

  • Dow strives to cover all uses of its products by customers and make these Identified Uses. Although Article 37.2 of the REACH Regulation suggests that only uses communicated at least 12 months before the relevant registration deadline must be considered by the registrant,  Dow will continue to consider uses communicated by customers after this deadline.

Note that also after the registration deadline (31 May 2013) customers have the right to make additional uses known to Dow. When a request is made by a customer to cover additional uses, Dow will start a dialogue with the customer to collect the relevant information needed to assess whether the requested use can be covered as an Identified Use.

  • To identify uses Dow takes the following approach for substances with common applications:
    • collect use information as available on the websites of sector organisations (e.g. Generic Exposure Scenarios, use mapping tables, etc.);
    • apply information on uses as available from the 2010 registrations;
    • when working in Consortia, cooperate with other companies on collection of use information.

Therefore, for common uses there is no need to pro-actively communicate use information to Dow.

  • For special uses,  Dow will start with internally describing such uses based on available information; however, when needed, Dow may choose to actively contact customers to verify the description of uses. When customers consider their use to be really different from the common uses mentioned above, they are invited to communicate information on their use to Dow. Please read more on the preferred process for communication on uses in  Communicate information on Uses to Dow

Should you still have questions or  concerns related to coverage of your uses, please contact our Customer Information Group .