28 October, 2021: Downstream User Import Notification (DUIN) deadline
Great British based companies that were considered downstream users or distributors under EU REACH before the exit date (31st of December 2020) are now considered importers under UK REACH. These companies now have the possibility to submit Downstream User Import Notifications – DUINs – for their substances to the HSE and benefit from extended registration deadlines (28th of October 2023, 2025 and 2027).
Are all substances eligible for DUIN?
No, only substances that were imported from the EU/EEA and were covered by an existing EU REACH registration or substances that were imported from outside the EU and were covered by an EU/EEA Only Representative (OR) can benefit from DUIN notification given that the GB importer must have been a downstream user or distributor of the substance in Great Britain in the two years prior to the end of the transition period. In other words, the supply to GB must have taken place between the 1st of January 2019 and the 31st of December 2020.
Who can submit DUINs to the HSE?
GB based importers and GB-based Only Representatives appointed by Non-GB suppliers can submit DUIN notifications to the HSE and this must be done by the 28th of October 2021, the DUIN notification deadline. When the appointed OR submits the DUIN, GB downstream users will be covered under this DUIN and do not have to submit their own.
What if I cannot benefit from DUIN?
For substances that have been EU REACH registered but cannot benefit from DUIN by GB based importers or GB-based Only Representatives, can get access to the GB market after taking part in a New Registration of Existing substance (NRES) process. In this process, the HSE may, after a successful inquiry, grant the registrant the possibility to defer the submission of the full information requirements to a later time so that the company can join the Joint Registration work and share data with other registrants of the same substance.
Do not miss out on your GB market access!
REACHLaw UK is happy to help you with the preparation and submission of the DUIN notifications for your substances. Through our office in the UK, we can serve you as either a UK REACH Only Representative or as a service provider in case you are a GB based importer or manufacturer.
Do not hesitate to contact us at firstname.lastname@example.org and ask for a detailed quotation for our UK REACH services specific to your case.