Example of when registration is needed: A manufacturer of a substance who uses the manufactured substance himself is a
manufacturer and a downstream user. He has a duty to register each substance
manufactured in quantities of 1 tonne or more per year, unless exemptions apply, and will
have to include information on his own use(s) and any identified uses of his customers in
his registration. An importer of a preparation has to register those substances which are present in the
imported preparation in quantities of 1 tonne or more per year, unless exemptions apply.
He will have to include information in his registration on the identified use(s) of the
substance(s) in the preparation. There is no obligation for importers of preparations to
register the preparations themselves; indeed preparations cannot be registered.
Example of when registration is NOT needed:
Any person, who is using substances which he has not manufactured or imported, is a
downstream user and has no obligation to register these substances. An importer of a substance, a preparation or an article, who is importing from a non EU
company who has appointed an “only representative” will be considered as a downstream
user and therefore does not need to register. A manufacturer or importer of a substance which is exempted from Title II of REACH has
no obligation to register that substance.
