Dow's objective is to be in compliance with all REACH requirements, as a manufacturer/importer, but also as a downstream user. That's why we have engaged in communication with our suppliers for clarification on downstream uses.
EU suppliers – making sure "business as usual" stays that way
In 2008 we worked with our EU suppliers to receive assurance of their pre-registration commitments. However, pre-registration does not necessarily mean a commitment to registration. Therefore, we are asking our EU suppliers to inform us as soon as possible if they do not plan to register one or more substances in the products they supply to us.
We need information about uses covered by your registrations
As a downstream user of all of our suppliers' substances, we need to make sure that intended uses of our products that contain our suppliers' substances are taken into account in their registration.
For this, Dow anticipates suppliers will follow the top-down approach on use communication as recommended by CEFIC. This means that Dow expects to receive information from its suppliers with respect to their identified uses for the substances contained in the products they sell to us. This notification should occur at the latest one year before the registration deadline for the substance. Dow will then have the opportunity to give feedback including exposure scenarios for the substances the suppliers indicate they intend to register and to make any additional uses known to our suppliers.
This communication with our suppliers will be handled centrally by our Subject Matter Experts.
Strictly controlled conditions
Suppliers wishing to inquire about the use under strictly controlled conditions (as defined in article,18 of REACH) of products purchased by Dow should contact us here.
Please visit our Self-service Center for additional information.
