DUIN notification
British companies that purchased registered substances from EU suppliers or through exclusive European representatives before BREXIT were classified as downstream users, but since 01/01/2021 they are classified as importers. This means that the obligation to register substances imported in quantities exceeding 1 ton/year must be carefully assessed.
However, UK REACH has provided a facility for all UK companies purchasing substances registered under EU REACH in the last two years before BREXIT, called DUIN notification, which allows an additional period of 2, 4 or 6 years for submission of the full registration.
DUIN notification can be submitted either by the UK importer or by exclusive representatives located in the UK named by articles’ manufacturers, formulators or producers located in the European Union.
DUIN must be submitted within 300 days of the end of transition period, so by 10/27/2021.
Normachem, with its UK office Normachem UK ltd, can assist UK companies in compiling notifications or can submit notifications directly on behalf of European companies acting as exclusive representative.
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