Do you use chemicals (downstream user)?
The UK has left the EU, new rules from January 2021
The transition period after Brexit comes to an end this year.
As a downstream user, you need to classify, label and package the chemical substances and mixtures that you place on the market in EU countries, in line with the CLP Regulation on classification, labelling and packaging (CLP).
You are a downstream user under CLP if you use a substance, either on its own or in a mixture, in the course of your industrial or professional activities. For example, you are:
- a formulator of mixtures, i.e. you use substances and mixtures supplied to you for the formulation of other products that you place on the market, e.g. adhesives, cleaning products, paints, motor oils;
- a re-filler who is transferring substances or mixtures supplied to him from one container of packaging into another;
- a re-importer who benefits from the exemption from registration under the REACH Regulation.
This means you should:
- make sure you understand what your duties are under the new CLP Regulation.
- make sure you understand the transitional periods to ensure that you re-classify, label and package on time;
- co-operate with others in your supply chain, to make sure the changes are managed smoothly;
- check that your chemicals are correctly classified and that your product labels are accurate.
All those in the supply chain are responsible for ensuring that substances and mixtures are labelled and packaged correctly before being placed on the market.