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REACH Authorisation
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Application for Authorisation submitted: the examination and opinion-making process

► The Authorisation is granted: what now?

The holder of an Authorisation is the one who submitted the Application for Authorisation.

  • A downstream user may continue his use of an Annex XIV substance provided that this use is in accordance with the conditions of an Authorisation granted to an actor further up his own supply chain for that use.
  • A manufacturer, importer or downstream user can continue placing an Annex XIV substance on the market for a use for which his immediate downstream user was granted an Authorisation in his own supply chain.
  • A company up the supply chain (for example, a formulator) can supply a downstream user holding an Authorisation for his use(s). However, as the use coverage of the Authorisation system is not bottom-up, the use of that supplier (that is, in this example, the formulation of the Annex XIV substance) needs to be covered by a separate Authorisation granted directly to him or to a company up his supply chain (for instance the manufacturer of the Annex XIV substance).

Distributors who only store the Annex XIV substance before placing it on the market should not be considered as Downstream Users in the context of Authorisation. It is advisable however to monitor what interpretation is given, in practice, to the notion of storage!

Do implement your substitution plan or your R&D plan!
Do get prepared for the renewal of your Authorisation if you know that no alternative will be available before the end of the validity of your Authorisation.
Do not stop working ! An Authorisation is time limited!

The materials and information included in this publication are provided
as a service to you and do not necessarily reflect endorsement by the
Nickel Institute. The Nickel Institute is not responsible for the accuracy
of information provided from outside sources.
Users are advised to seek their own professional advice.