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EU REACH · ARTICLE 66
Article 66 – Downstream User Notification
Notification duties for downstream users making use of a substance once it has been granted authorisation.
Using an authorised substance without losing sight of the paperwork.
Once a substance of very high concern has been added to the Authorisation List, its listed uses require an authorisation before they can continue. Article 66 sets out the obligation on downstream users who rely on an authorisation granted further up their supply chain: they must notify the European Chemicals Agency (ECHA) of their use of the substance within the required period after first receiving it, and are entered onto ECHA’s downstream user register.
This matters because an authorisation is granted for specific uses and conditions, not for a substance in general. A downstream user needs to check that its own use genuinely falls within the scope of an authorisation already granted to a supplier, rather than assuming that receiving the substance is enough.
For more on how the Candidate List and Authorisation List work, and what they mean for your organisation, see our guide to Substances of Very High Concern (SVHCs).
✓Checking whether a specific use falls within the scope and conditions of an existing authorisation
✓Managing the downstream user notification to ECHA and its timing
✓Maintaining records that demonstrate use consistent with the authorisation’s conditions
✓Planning ahead where a use may need its own authorisation route or substitution instead
✓Creating and maintaining a central substance repository alongside your bill of materials, so the underlying data does not live in scattered spreadsheets
✓Helping you understand the trigger points for Article 66 and where your organisation’s role and duties sit in the wider REACH supply chain
When does the Article 66 notification duty trigger?
Article 66 only applies to downstream users relying on an authorisation granted to someone else in the supply chain. The path below shows how that is established.
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Check the Authorisation List
Is the substance you use listed on REACH’s Authorisation List, meaning its use now requires specific authorisation?
Confirm your role
Are you a downstream user relying on an authorisation already granted to a supplier, rather than the authorisation holder yourself?
Check scope and conditions
Does your specific use fall within the scope and conditions of that granted authorisation?
Notify ECHA
If so, you must notify ECHA of your use within the required period after first receiving the substance.
Register and maintain records
Your use is entered on ECHA’s downstream user register, and records must be kept showing use consistent with the authorisation’s conditions.
How we help with Article 66
The hardest part of Article 66 is usually establishing whether a specific use genuinely sits inside someone else’s authorisation, before the notification itself is even drafted.
Identifying substances that trigger notification
We check Authorisation List status for the substances you use, and assess whether your specific use falls within the scope and conditions of an authorisation already granted upstream.
Recording and evidencing the assessment
We build and maintain records showing how your use meets the authorisation’s conditions, ready to support the notification and any later review.
Drafting and provisioning the notification
We prepare the ECHA downstream user notification itself, so your use is properly recorded on the downstream user register within the required period.
Managing supply chain and regulator communications
We liaise with the authorisation holder or supplier on scope and conditions questions, and act as the point of contact with ECHA on notification queries.
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Tell us where the uncertainty sits. We will help you define the requirement and the right level of support.
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