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REACH | 1st March 2018

ClientEarth’s comments on ECHA’s position paper related to Downstream User notifications
REACH
Chemicals

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ClientEarth’s comments on ECHA’s position paper related to Downstream User notifications

An authorisation to use a substance of very high concern can be requested by a company for itself, for its downstream users, or for both. When downstream users are covered by such an authorisation, they have to provide some information in a notification to ECHA in order to clarify which substance they use, how and why.

ECHA released in March a draft paper outlining what its policy on the publication of this notification would be. As these notifications give the public crucial information on how dangerous substances are used in the territory of the Member States, ClientEarth analysed this draft and made proposals for a more ambitious approach.

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