UK REACH Update: Imminent deadlines and challenges


While it is nearly a year into the post-Brexit chemicals regulatory regime, the infrastructure to accommodate UK REACH registrations is not yet running smoothly and as a result importers and distributors of chemical substances are struggling to fulfil their obligations in time. For those companies that have not yet completed their registrations or notifications – and even for those companies that believe the necessary steps have been accomplished – updated functionality in the “Comply with UK REACH IT” platform and other developments make this an appropriate time to review their obligations for compliance purposes. Importers and distributors of chemicals from the EU into the UK must act now, as they have only a few days left in order to benefit from available transitional arrangements.


Deadline for Submitting DUIN Registrations Is 27 October 2021

Prior to Brexit, companies based in the UK that sourced chemical substances from EU suppliers above one tonne per year were considered as downstream users and were not obliged to register. Under UK REACH, such UK entities are treated as importers. In order to be able to continue supplying the substances from the EU without having to register them until 27 October 2023, 2025 or 2027 (depending on the tonnage band and/or hazard profile of the substance), UK importers have to submit a Downstream User Import Notification (DUIN) to the UK Health and Safety Executive (HSE) by 27 October 2021.

The process is straightforward; only the following information needs to be emailed to UK HSE:

DUIN number, obtained by indicating on UK REACH IT that the company is an existing downstream user;

Legal entity name; and

Information on the substance(s) imported from the EU (i.e., substance name, CAS or EC number).

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JDSupra, 20 October 2021