November 15, 2021 by Sylwia Kosmala-Grzechnik
As the UK is no longer part of the EU, any company intending to import a substance into the UK, at or above 1 tonnes per annum (tpa), has to submit a registration to the UK authority, the Health and Safety Executive (HSE).
However, transitional arrangements have been put in place to help minimise the impact of introducing new legislation on the chemical industry and disruption to in the supply chain. This includes the grandfathering of EU REACH registrations, and the submission of a downstream user import notification (DUIN). By grandfathering the EU REACH registrations or submitting a DUIN, companies are allowed additional time of 2, 4 or 6 years plus 300 days after the end of the transition period to meet their full registration obligations under UK REACH.
Downstream user import notification (DUIN)
UK-based companies, who were downstream users or distributors of EU REACH registered substances in the 2 years prior to 1 January 2021, or EU-based companies regarded as a downstream user through an Only Representative (OR) appointment, could take advantage of the extended deadlines for registration obligations by submitting a DUIN by 27th October 2021. The UK government has now highlighted that they have re-opened the possibility for DUIN submission. This means that companies that missed the original deadline for submitting the DUIN can still submit a DUIN to allow them to continue importing substances into the UK in quantities above 1 tpa. Companies who would like to benefit from this extended deadline are recommended to submit their DUIN as soon as possible.
Companies should be aware that by submitting the DUIN they only defer the registration obligations and, if they are planning to continue importing the substance into the UK after the end of the extended registration deadlines of 27 October 2023, 2025 or 2027, they should follow the registration process for the substance. In such case, an inquiry dossier according to Article 26 of UK REACH should be submitted as a next step. It is advised to do this as soon as possible to be able to participate in the discussion on the data sharing and appointment of the Lead Registrant.
What next?
Following the deadlines for DUIN submission, the next step is to submit inquiry dossiers in order to join the substance groups which allows companies to contact other (potential) registrants and arrange the preparation of joint datasets. Inquiry dossiers are required for every substance which you intend to register, and there are substance and company specific fields which need to be completed in order to submit the inquiry dossiers. The inquiry (and subsequent registration) dossiers must be submitted in IUCLID format.
wca staff are experienced users of IUCLID and we can use our IUCLID software to prepare your dossier. After successful acceptance of the inquiry by HSE and joining of the substance group, wca can also assist with the next steps in accessing data and joining the joint submission, ready to submit the full registration.
If you are looking for assistance with your next steps under UK REACH, be that previously grandfathered registrations or inquiries for new or DUIN substances, or if you are looking for a UK OR, we can assist you. If you are interested in any of these services, or need any help with your obligations under UK REACH, please do not hesitate to contact us and we can discuss with you how to proceed.