UK REACH: Late Downstream User Import Notification (DUIN) is possible

The awaited UK REACH Downstream User Import Notification – DUIN – deadline finally took place last week on the 27th of October 2021. Companies eligible for DUIN, that submitted their notifications for their substances in time to the HSE, will benefit from extended UK REACH registration deadlines as follows: 27 October 2023, 2025, and 2027 depending on the annual tonnage and the hazards of the substance.

What if you missed the DUIN deadline?

According to new information from the HSE, companies, including Only Representatives, eligible for DUIN that didn’t notify their substances by the deadline and wish to continue importing EU REACH registered substances into the GB market at 1 tonne or more per year, can still submit late-DUIN notifications. The HSE recommends doing this as soon as possible.

What substances are eligible for late-DUIN?

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 late DUIN notification given that the GB importer must have been a downstream user or distributor of the substance in GB between the 1st of January 2019 and the 31st of December 2020.

Which companies are eligible for late DUIN notification?

GB based importers and GB based Only Representatives appointed by non-GB suppliers (as non-GB manufacturer/formulator) can submit late-DUIN notifications to the HSE. When the appointed OR submits the late-DUIN, GB downstream users will be covered under this DUIN and do not have to submit their own.

How long will late DUIN notification be possible?

This is currently not known and therefore, it is highly recommended to submit your late DUINs as soon as possible to avoid any interruptions in your supply of chemicals to the GB market.

How REACHLaw UK can help you with your late DUINs?

REACHLaw UK is happy to support you with your late DUIN notifications as your Only Representative or as your service provider for you as a GB based importer.

Do not hesitate to contact us at sales@reachlaw.fi , for assistance. Asking for a quotation is quick and easy and doesn’t cost anything.

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