DUIN and UK REACH: until October 27th to remain compliant
Implemented in January 2021, UK REACH is the UK version of the European REACH regulation on the registration, evaluation and authorisation of chemicals in Europe. It fills the legal gap left by the latter following the UK's exit from the European Union and brings new obligations for all companies operating in the UK. .
For example, companies based in the UK that were previously considered downstream users of substances registered by EU27, companies under EU REACH now become importers of chemicals under UK REACH. They are therefore obliged to register these substances under UK REACH with the HSE (Health and Safety Executive).
In order to ease the burden of obligations on these companies, the UK authorities have introduced a simplified process: Downstream User Import Notification (DUIN). The DUIN allows UK companies to notify the HSE of their import of a chemical substance from the EU or from a non-EU country under an agreement with an EU-based only representative.
If this notification is made before October 27th, 2021, it will give an additional 2, 4 or 6 years before the substance has to be fully registered under UK REACH. It is therefore an essential step to remain compliant while spreading the costs and procedures in time: companies that do not complete it in time will have to register their substances directly via a full dossier.
DUIN, how to do it and what steps to take afterwards?
In order to proceed with DUIN, companies must go through the dedicated Comply With UK REACH IT platform set up by the UK Government. They must fill in the basic information and indicate that they are distributors or downstream users.
The notification should then be filled in with the information on the substance relevant for its further import, using the template available on this page. The completed spreadsheet should then be sent to ukreach.dunotification@hse.gov.uk with the name of the legal entity and the previously obtained DUIN number in the subject line. It may be useful to attach the Safety Data Sheet (SDS) of the substance.
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After DUIN, companies will have to complete a full registration of their substances by the following deadlines:
- October 27th, 2023 for substances produced or imported at more than 1000 tons per year as well as for CMR substances (carcinogenic, mutagenic or reprotoxic) at 1 ton or more per, substances extremely toxic to aquatic organisms at more than 100 tons per year, as well as for all substances on the Candidate List as it was on 31st December 2020.
- October 27th, 2025 for substances of 100 tons or more per year, as well as substances on the candidate list as of October 27th, 2023.
- October 27th, 2027 for substances of 1 ton or more per year.
To make a registration, companies will have to start with an inquiry (Article 26) in order to obtain information on a potential existing registration, etc. They must then submit their registration jointly with other companies wishing to register the substance, sharing data, with a Lead registrant and Member registrants.
As a specialist in REACH and REACH-like regulations, EcoMundo can assist you in the compliance of your substances, whether it is for DUIN, for a full registration or for any other regulatory issues.
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