UK REACH: HSE provides clarification on the requirements to perform DUIN

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In an email exchange with GPC dated April 2nd, 2021, HSE provided a much-welcomed clarification regarding the requirements that non-GB manufacturers must meet in order to qualify for DUIN.

In their email, HSE stated that DUIN is only available for companies that imported/used EU REACH-registered substances into Great Britain (GB) in the two years before the end of the Transition Period (1st January 2019 - 31st December 2020). Alternatively, a non-GB manufacturer may submit a DUIN via a GB-based Only Representative (OR) in order to maintain access to the British market. In this case too the availability of DUIN is conditioned upon the substance being placed on the British market in the two years before the end of the Transition Period.

On the opposite, if a substance is imported into Great Britain after the end of the Transition Period as part of a new supply chain, then the criteria to submit a DUIN are not met. The importer will therefore be required to carry out the full registration of the imported substance, unless the non-GB based manufacturer of that substance appoints a GB-based OR to fulfill that obligation on behalf of the importer.

Last update: 2021-04-05