UK REACH Downstream User Import Notifications: the clock is ticking... don’t be left on the shelf

Written By Kaying Tam

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The 27 October 2021 deadline for Downstream User Import Notifications (DUIN) is fast approaching. Act now to benefit from the “protected transitional import” provisions of UK-REACH.

GB companies who imported EU REACH registered substances (either directly or via an EU Only Representative) between 31 January 2018 - 31 January 2020 can take advantage of the DUIN process.

Non-GB companies who supplied EU-REACH registered substances (between 31 January 2018 - 31 January 2020) into Great Britain can appoint a GB Only Representative to submit a DUIN for these substances. 

Advantages of a Downstream User Notification

DUIN data requirements are relatively light, the key information required is largely administrative rather than technical or scientific and there are no fees payable to the authorities.

A DUIN allows the submitter to continue to be regarded as a downstream user, even though they may now be an importer, and also defer their obligation to register a substance for up to 6 years after 28th October 2021.

Ultimately, a Registration will be required to be made by the GB importer or perhaps another actor higher in the supply chain or an Only Representative acting on behalf of the non-GB supplier.

For companies who submit a DUIN before the deadline, the Registration deadlines are within 2, 4, or 6 years of October 28, 2021, depending on the tonnage band and hazard properties of the substance.

chart duin.PNG

Alternatively, as a GB importer, you can encourage your supplier to appoint a GB-based Only Representative (OR) or you can look for a GB supplier who already has a UK-REACH Registration.

If you fail to submit a DUIN by the deadline, imports may be non-compliant and you may face penalties. You may have to cease importing until a Registration can be put in place and this typically takes several months to complete.

Although UK-REACH has retained the same principles and requirements as EU-REACH, the Registration process is quite lengthy. For this reason, Yordas recommends that businesses use the DUIN option to benefit from the extended Registration deadlines and avoid supply chain disruption.

Only Representatives (ORs)

GB Only Representatives (ORs) can submit DUINs, Grandfather EU-REACH Registrations, and submit Registrations in the same way as other GB registrants. However, ORs can cover multiple GB importers in a single DUIN or Registration.

Learn more about upcoming UK REACH deadlines

Watch our free webinar ‘UK REACH - Summer 2021 Update’ to learn more about Downstream User Import Notifications, NRES dossiers, Registration, and other REACH-related developments/updates.

How can Yordas help?

Providing UK Only Representative services for non-GB companies

  • Clarifying your regulatory obligations under both UK and EU REACH

  • Grandfathering substances into UK REACH, where existing EU REACH registrations are available

  • Submitting New Registration of an Existing Substance (NRES) and New Registration dossiers under UK REACH

  • Submitting Downstream User Import Notifications under UK REACH

  • Conducting data access and cost-sharing negotiations

  • Preparation of dossiers in IUCLID format

If you wish to discuss any of the points above, or any other aspect of UK REACH compliance, send us a message here.

Kaying Tam
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