There is no obligation for a downstream user (DU) to register a substance. However, a downstream user should check with his supplier if he has or intends to register the substance of interest under REACH.
A DU has the obligation to check whether his use is covered by the conditions described in an exposure scenario attached to the extended Safety Data Sheet (e-SDS). In case, where the DU does not want to make his use known to his supplier or where the supplier does not support the identified use for health or environment protection reasons, or where the DU does not regard his supplier’s exposure scenario as appropriate and wishes to make his own, a CSR has to be submitted by the DU. However, a DU does not need to prepare a CSR if he uses the substance or preparation in a total quantity of less than 1 tonne per year.