Declaration of conformity



Regulation (EU) No. 1907/2006 (REACH)


As formulator we are considered within the scope of the regulation (EU) No. 1907/2006 (REACH) as downstream user. Downstream user are defined in article 3 No. 13 as “natural or juristic person based in the community, that use within the scope of their industrial of their industrial or commercial activity such a substance or use it in a formulation”.


In the main we have to fullfil the information duty according to the title IV (information in the supply chain) and V (downstream user) of the regulation. This includes the compliance with the risk minimisation measures, the disclosure of information within the supply chain (safety data sheet) as well as the storage of information. According to article 34 this contains also the disclosure of new information to the downstream actor in the supply chain (your supplier) about dangerous features of a substance and further information, that could challenge the qualification of the transmitted risk minimisation measures.

In exceptional cases an evaluation of the substance´s safety according to article 37 has to be effected.


Further information about the subject “downstream user” can be found at the website

Formulations can not be registered under REACH.



June 20, 2019

Franck Favre

Managing Director




Antibes (France)

+33(0)6 88 31 08 88