SDS Studio™Definition: A downstream user is any EU company, other than the manufacturer or importer, that uses a substance on its own or in a mixture in its industrial or professional activities, for example a formulator.
Formulators who mix purchased raw materials into their own products are downstream users. They must follow the supplier SDSs and exposure scenarios and supply their own SDSs to their customers.
Distributors who only store and resell are not downstream users, but they still pass on SDSs.
Legal anchor: REACH Article 3(13). A downstream user is a natural or legal person established in the EU; distributors and consumers are not downstream users. Obligations: Articles 37 to 39.