Over the past 300 days GB based companies who previously held EU REACH registrations had the opportunity to grandfather their substances into the new UK REACH system. Similarly, GB based companies who benefited from the EU RECAH registration of their suppliers also had the opportunity to submit a DUIN to comply UK REACH.
Since the beginning of UK REACH the HSE as the governing UK REACH authority has maintained open communication with the chemicals industry to ensure that companies can continue to operate in the UK and remain compliant with the regulations. With the deadline for DUIN (27th of October 2021) now passed the HSE has shared further updates for companies who may have missed this deadline for their substances. As has been made clear by the HSE, the DUIN will grant a tonnage band dependant Grace Period to companies that complete it, suspending the registration obligations during that time.
DUIN – Post 27th of October 2021 Deadline
Prior to the October 27th DUIN Deadline the HSE was urging all eligible companies to submit a DUIN for as many substances as possible. In a recent communication from the HSE they have indicated that the DUIN provision may remain open after the 27th of October. We understand that this will allow companies to submit further DUIN where information becomes available to them after the deadline. This is a similar action that was seen following the Grandfathering Deadline, where the HSE continued to accept Grandfathering applications on a case-by-case basis.
Additional DUIN Tips from CIRS
- DUINs only apply to EU REACH registered supply chains.
- Keep records of the products you imported/used when you were a Downstream User before the end of the transition period to demonstrate that you were a downstream user.
- Keep records of communications with suppliers where you have been requesting information to support your DUIN submissions/ UK REACH compliance.
- Submitting a DUIN does not mean you are then obligated to follow through with a registration.
If you have any questions or would like to enquire about any of the services we can offer your business, please feel free to contact us as we would be happy to help.
Senior Regulatory Consultant, CIRS Europe