UK REACH Reminder: Downstream User Import Notifications (DUINs) Deadline 27.10.21

It may well be that you’ve gone from downstream user under EU REACH to importer under UK REACH. Our UK REACH page has a useful section with HSE links on the change between a downstream user under EU REACH to an importer under UK REACH. The following details your options should you be an importer:

REMINDER: Downstream User Import Notifications (DUINs) are required by 27 October 2021

If you are importing substances into the UK from a non-GB based entity there are two options:

• Import substances from a non-GB based supplier who has appointed an Only Representative (OR) in the UK to hold the registration and supply the substance
• Register the substance(s) yourself, which requires an initial DUIN to be submitted by 27 October 2021

The DUIN process enables existing supply chains to continue and allows businesses time to determine how best to comply with the registration obligations under UK REACH. 

However, to keep the chemical substances in their supply chains on the UK market, businesses need to make sure that the relevant substances are eventually registered for UK REACH purposes.

You will be able to make use of this notification provision if you:

• Have acquired importer obligations under UK REACH as a previous downstream user or distributor of a substance covered by an EU-based registration, or
• you were previously covered by an Only Representative in the EU/EEA you are able to make use of this notification provision to ensure continuity of supply.

Downstream users can notify the HSE of their intention to continue importing substances from the EU or EEA by 27 October 2021 using a Downstream User Import Notification (DUIN).

For more information, the BPF post-Brexit hub has our UK REACH page: https://www.bpf.co.uk/eu/uk-reach.asp