Document EqXXLwXmDOOELZV2B9MRyMaR

@Geenevte @JBve wescozansssse sono: DOWNSTREAM USERS - 10 PRIORITIES FOR THE REACH REVISION 1 AVOID INCREASING THE DEMANDFOR ANIMAL TESTING `With many of its members as active participants of EPAA (theEP uroa per an tnerfos rAlh teri natp ive `Advancements in Non-Animal Methods/ New Approach Methodologies (NAMs) need to be reflected in 2 `A TARGETED MIXTURE ASSESSMENT FACTOR testing. These impacts cannot always be mitigated. The MAF should be applied only to substances that, based on their characteristics, can end up in an unintended mixture and, if so, contribute to the mixture toxicity. Unintentional co-exposure has spatial are persistent, respectively, the focus of MAF should be on PBTs that are used in high tonnages and widedispersiveuses. 3 "PROFESSIONALS WHERE EXPOSURE PATTERNS ARE SIMILAR TO CONSUMER USES Professionals should not be treated like consumers. Professional users normally receive adequate information and training on handling hazardous substances and apply other risk management measures - this professionalism should be recognised. DUCC is open to further engaging in training for professional users as a better solution to generic bans. 4 `GENERIC RISK MANAGEMENTAPPROACH Downstream users wish to be part of the solution and a robust implementation of GRA. A crucial point for downstream users, is the importance of a practical, effective procedure, that will have a workable Ifa substance can be usedsafely while alternatives are explored, enough implementation time That elimination of an entire product category should be considered enough of an impact for a 1 Make essential use a complementary tool for decision making, a the lat step in the process, but not the main driver for regulatory decisions. Any assessment of essential use should be the result of an in-depth review performed by the right experts, in which stakeholders should have the possibilty to comment on a draft decision and appeal anyfinaldecision.The definitionofessential should also consider the wide rangeof sustainability, social `and economic benefits that a substance can bring when incorporated in a product, The concept must also allow for societal changes. Polymers are used ~and often made/customised -- in Downstream Users products for a wide variety of applications and benefits. DUCC encourages the Commission to implement requirements to register only polymers that pose concerns and avoids overload of the system. DUCC has collected information on the impacts of the different policy options for registration of polymer.s EJDUCCstatements Downstream users need data from upstream to be able to carry out risk assessments, and problems arise if this data is missing. DUCC supports giving ECHA an increased mandate to revoke REACH registration numbers of repeat offenders. DUCE supports the introduction of a requirement for the electronic provision of Safety Data Sheets. Thisi provided that the possibility to send Safety Data Sheets in pdf, email and/or other electronic formats, including but not mitedto the XML format, i included. DUCC does not supporta for detailed information to be required systematically for all substances used by downstream users. There are different scenarios where information on use and exposure can be provided, but the level of detail to be provided should be case specific, depending on the level of concern, available data etc. to ensure a workable system. Every actor in the supply chain should have the possibilttoy provide information on uses as relevant. Different actors may be more appropriately placed to provide information. With the increasing requirements in the revision of REACH promptedbythe CSS, it is important that ECHA will have public funding and expertise to manage new tasks and to provide necessary guidance `on compliance for industry. 2