Dow's objective is to be in compliance with all REACH requirements, as a manufacturer/importer, but also as a downstream user. That's why we have engaged in communication with our suppliers for clarification on downstream uses.
EU suppliers – making sure "business as usual" stays that way
In 2008 we worked with our EU suppliers to receive assurance of their pre-registration commitments. However, pre-registration does not necessarily mean a commitment to registration. Therefore, we are asking our EU suppliers to inform us as soon as possible if they do not plan to register one or more substances in the products they supply to us.
We need information about uses covered by your registrations
As a downstream user of all of our suppliers' substances, we need to make sure that intended uses of our products that contain our suppliers' substances are taken into account in their registration.
To achieve this, Dow will follow the same approach as it is taking for its own registrations:
- Dow expects suppliers to register common uses of the substances contained in the products they sell to us. When a supplier is not intending to register a common use of such substances, Dow expects the supplier to notify Dow as soon as possible (preferably before 1 June 2017).
- For special uses, Dow expects suppliers to actively contact Dow as soon as possible (preferably before 1 June 2017) on the description of such uses and related exposure scenarios. Dow will provide feedback on the proposed identified uses and exposure scenarios and, when considered appropriate, initiate a dialogue with the supplier. Such communication will be handled through our Subject Matter Experts.
Strictly controlled conditions
Suppliers wishing to inquire about the use under strictly controlled conditions (as defined in article 18 of REACH) of products purchased by Dow should contact us.