UK REACH DUIN: Do You Meet the ‘Existing Supply’ Conditions?

  • November 7, 2025
  • Rachna Nayyar, Regulatory Manager, REACHLaw UK

Unsure if your supply qualifies for a UK REACH DUIN? Let’s clear it up!
Many businesses affected by UK REACH registration requirements are still unsure what existing supply means when it comes to submitting a Downstream User Import Notification (DUIN) under UK REACH, and whether they are eligible.  You are not alone in this!

Here’s a concise overview:

Existing Supply Chain: What you need to know
To qualify for a Downstream User Import Notification (DUIN), your substance must have been part of your existing supply chain in Great Britain before 1 January 2021. “Existing supply” can include:
  • Direct import or manufacture: The substance was already being imported or manufactured for your GUK business.
  • Downstream user supply: You were using the substance in your processes or products under EU REACH.
  • Distribution via an Only Representative (OR): You relied on an EU-based OR to register the substance on your behalf.
What’s a DUIN?
A DUIN allows businesses that were dependent on EU REACH registrations before Brexit to continue importing substances into Great Britain (England, Scotland, and Wales) without the immediate need for full UK REACH registration by the designated registration deadlines applicable to these substances. Essentially, it’s a temporary measure to keep supply chains running smoothly in the UK market.

If the conditions above applied to you, you should have submitted your DUINs to the Health and Safety Executive (HSE) by October 27, 2021.

Missed the DUIN deadline?
If you missed the DUIN submission deadline but believe your supply chain met the above conditions, you might still be able to make a late DUIN notification. However, you should act as soon as possible.  Ensure you can demonstrate that the supply existed before January 2021 and that you were a downstream user, distributor, or used an OR arrangement.
Key points to assess your eligibility:
  • Timing matters – Only substances supplied before 1 January 2021 qualify. New suppliers after this date cannot rely on a DUIN.
  • Volume thresholds – The DUIN applies to substances above 1 tonne per year; check your import or production volumes.
  • Documentation – Evidence of purchase orders, invoices, or contracts showing supply before 2021 can help support your eligibility for DUINs.
If your substance does not meet the specified conditions, you must register it with the HSE before placing it on the UK market. This can be achieved by submitting a New Registration for an Existing Substance (NRES) or a new registration for a new substance. The appropriate option will depend on whether your substance is considered as an existing or new one under UK REACH.
 
Stay tuned! Next week, we will explore the specifics of NRES and New Registration for a new substance under UK REACH.
Meanwhile, need help with your DUINs? Contact us at sales@reachlaw.fi for support.
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