4	FAQ: DOWNSTREAM USERS
	4.1	Is there a tonnage trigger for the DU obligation to conduct a CSR?
	4.2	Exemption from general obligation of registration for product and process oriented research (PPORD), how will notification work for Downstream users? How can they get a substance from a supplier if it is for an unidentified use and will they have to reveal the necessary information for notifying the agency to their supplier? Or is there no protection of research by DUs?
	4.3	At present, a significant part of substances and preparations on the market are lacking of MSDS or of SDS accuracy. Which modifications shall be expected in the frame of Directive 2001/58/EC, especially in the view of the downstream users, which will have to verify the already covered intended use of the purchased substances and preparations?
	4.4	How will DUs get information about the substances covered by REACH?
	4.5	A DU is required to pass on up stream (new) information he receives. The DU is therefore required to inform supplier 1 (let us assume he is in the 10-100 tonnes per year range) about the data/information he has received from supplier 2 (let us assume he is in the >1000 tonnes per year band), both producing the same substance. Does supplier 1 need to use ALL available data when registering, including studies that might have been produced by supplier 2 to produce the SDS information provided by supplier 2 to the DU?
	4.6	According to Art. 32(1)(a), all actors in the supply chain of a substance or a preparation who do not have to supply a SDS, have to supply the registration number(s) of the substance(s), if available. A strict interpretation of this means that even for very low concentrations of not dangerous substances in preparations, the supplier will have to identify the substances towards his customers and therefore also provide detailed information on his product.
PRINT [www.reach-compliance.eu]