Time to Act - Less than One Month Until the UK REACH DUIN Deadline

Introduction

Since the beginning of UK REACH the HSE as the governing authority has maintained open communication and with the chemicals industry to ensure that companies can continue to operate in the UK and remain compliant with the regulations. With the upcoming deadline for DUIN (27th of October 2021) the HSE has shared further updates for companies who are considering or in the process of completing their DUIN applications. Below is an outline of the most important information that has been recently released which will be of great interest to those companies.

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. The DUIN submissions are currently open until the 27th of October 2021 for companies that meet the following criteria.

  • A company based in Great Britain (GB) who’s supplier (either a GB or non-GB based company) held an EU REACH registration and was a downstream user of that supplier in the two years prior to the end of the Brexit transition period (31st of December 2020).
  • An Only Reprenetative based in Great Britain (GB) who has been appointed by a non-GB Manufacturer or Formulator that currently holds an EU REACH registration and imported the substance to the UK in the two years prior to the end of the Brexit transition period (31st of December 2020).

For the majority of these companies processing of the DUIN should be straight forward, obtain your DUIN number from the Comply with UK EACH IT system and then submitting information such as Chemical Identifiers, Company Information and REACH Information to the HSE directly.

“To the extent that it is available” – Practical DUIN Solution of Polymer and Mixture

At CIRS we work very closely with our clients to address their most pressing issues. The HSE is urging all eligible companies to submit a DUIN for as many substances as possible before the October 27th Deadline as this is their only opportunity to suspend the full registration obligations. However, many companies have reported issues with obtaining the required chemical information for Polymers, Mixtures and Unknown Substances in the products they import. In general, the HSE has stated that information for the DUIN should be provided “to the extent that it is available”, while also providing further guidance for specific situations as outlined below.

  • Polymers: As under EU REACH, Polymers themselves are exempt from registration under UK REACH, but the monomers that make up the polymers are required to be registered and as such it is possible to submit a DUIN for those monomers.
    • Companies that import Polymers may not have access to the monomer information for that polymer. The HSE have advised that for common polymers to use the “best guess approach”, that is to say, provide the most likely monomer information based on the likely composition of that polymer.
  • Non-Hazardous Mixtures: As non-hazardous mixtures do not require the individual substances to be listed in a SDS it can be difficult to determine what substances make up those mixtures.
    • In this case again the HSE recommends the “best guess approach" and is discouraging companies from submitting the product/formulation names as there is little substance information obtained from them.
  • Unknown Substances: Substances that are contained in products/formulations that may not be identified to your company.
    • The HSE has stress that you can’t tell them what you don’t know and should focus on what you do know.
    • A DUIN can be submitted with just the following information
      • Company Identification
      • Product Information
      • EU REACH Information

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.

CIRS is now hosting a series of free webinars on chemical registrations in Asia and Europe from Sept. 22 2021 to Nov. 3 2021. The webinar on UK REACH has closed and the video replay is now available on our website. To know more upcoming events on chemical registrations in Asia and Europe, please click here.

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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.

Author Information

Dean Winder

Senior Regulatory Consultant, CIRS Europe

Email: service@cirs-reach.com