It is expected that suppliers to the additised fuel supply chain will be aware of approximately 80% of the uses of their substances/products. The ATC FA GES WG therefore recommends that EU manufacturers and/or importers responsible for the registration of substances and formulators adopt the CEFIC/FECC-endorsed “top-down” communication workflow for Identified Uses and associated Exposure Scenarios. It is the intention of the ATC FA GES WG members to cover, and/or encourage their suppliers to cover, the supported additised fuel applications and Use descriptors included in the Fuel Applications Table (Section 7.2) and the Fuel Use Description for Tier 1 Exposure Assessment Tables (Section 7.3) in their registration dossiers.

The following steps should help you identify whether your use of a substance/product supplied to you has been assessed as part of this project and assigned a set of Fuel Use Descriptors by the WG:

Step 1: Refer to the Fuel Application Table (Section 7.2) to confirm that your application is listed.

Step 2: Refer to the Additised Fuel Use Description for Tier 1 Exposure Assessment Tables (Section 7.3.1) to identify the Sector of Use (SU), Product Category (PC), Process Category (PROC), and Environmental Release Category (ERC) that has been assigned. (Note that additional information on exposure criteria will be provided in section 7.3.2 and 7.3.3 in a future update to these web pages).

Step 3: If your additised fuel application is covered by the provided Use Descriptors, there is no need to take further action since it is likely that your Use will be covered by the upstream suppliers in their registration dossier.
If your additised fuel application is not adequately described by Steps 1-3 then it is recommended that you contact your Supplier as soon as possible if you want the manufacturer/importer to include your specific use in their registration dossier. In accordance with REACH you, as a Downstream User, can ask the manufacturer/importer (even if it is by way of your supplier who may be a formulator) to include your use in the registration dossier.

However, this communication has to be completed at least 12 months before the respective registration deadline and meaning that for substances with a 1st December 2010 registration deadline this has to be completed by end November 2009 at the latest.

If you decide not to make your particular use known to the manufacturer/importer, or the manufacturer/importer has already informed you that they will not support a particular use because it is deemed not safe, then you may have to develop your own CSA for this use and inform ECHA (see Guidance for Downstream Users), assuming you would like to continue the particular use.

Please note that the process described above is also a feedback loop that will help in the development of the Additised Fuel Applications Table. The ATC FA GES WG has used their best endeavours to ensure that this table covers all the different applications of additised fuel and fuel additives but it is understood that language and nomenclature may differ between individual companies across this sector and so identification of your specific use in the table may be problematic. If you are unable to identify your specific use in the table and you would like to see your particular application included in this project then you should contact your supplier for further discussions.