Use Communications 2018 Registrations
Directly after the successful completion of the substance registration for the REACH 2010 and 2013 timeline, Dow started to prepare for the next registration deadline based on the experiences gained and the best practices identified. During the preparation of the 2010 and 2013 registrations, Dow has collected use information by applying a top-down (i.e. from manufacturer/importer to downstream user) as well as a bottom up approach. In the bottom up approach Dow has utilized information on uses and use conditions provided by sector organizations in formats as Generic Exposure Scenarios and Use Maps. The Use Map format has been further developed over the last 2-3 years and has resulted in an improved format to provide information on the uses of chemicals in a harmonized and structured way. This format is supported by the main industry associations as well as by ECHA. For more information on Use Maps, consult the ECHA website.
For the 2018 registrations Dow will mainly apply the bottom up approach for collecting use information, but will also use the top down approach where needed. 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 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 Maps) or ECHA;
- apply information on uses as available from the 2010 and 2013 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 us.