• Manufacturers, importers and downstream users have to classify substances or mixtures before placing them on the market;
  • Suppliers have to label and package substances and mixtures placed on the market;
  • Manufacturers, producers of articles and importers have to classify those substances not placed on the market that are subject to registration or notification under REACH Regulation (EC) No 1907/2006.
  • Manufacturers and importers have to notify the classification and labelling elements of their substances to ECHA if these have not been submitted as part of a REACH registration. This notification also applies to hazardous substances placed on the market (import is deemed to be placing on the market (CLP Article 2 – definition of placing on the market)) either on their own or in a mixture above a concentration resulting in the mixture being classified as hazardous.

 

‘Supplier’ means any manufacturer, importer, downstream user or distributor placing on the market a substance, on its own or in a mixture, or a mixture.

‘Downstream user’ means any natural or legal person established within the Community, other than the manufacturer or the importer, who uses a substance, either on its own or in a mixture, in the course of his industrial or professional activities. A distributor or a consumer is not a downstream user (same definition as under REACH). A re-importer exempted pursuant to Article 2(7)(c) of Regulation (EC) No 1907/2006 (i.e. substances already registered by an actor up the supply chain) shall be regarded as a downstream user.

‘Distributor’ means any natural or legal person established within the Community, including a retailer, who only stores and places on the market a substance, on its own or in a mixture, for third parties.