Find answers to some of the most frequently asked questions below

We have received a number of questions pertaining to UK REACH, Downstream User Import Notifications (DUINs), Only Representative (OR) responsibilities and overall who in the supply chain is responsible for the compliance. 

To help with the confusion around the new UK REACH regulations and to clarify the differences between UK and EU REACH, our Senior REACH Consultant, Laura Clement, has recorded a FAQ video, answering the most frequently asked questions.

Below, we have answered the other important questions we have received. If you have a bespoke question or need support with any aspect of UK REACH, please contact us.

General questions

Can I update or resubmit my DUIN?

After the deadline of 27 October 2021 has passed any substances that have not been included on your DUIN will require immediate registration.

Can you clarify the definition of importer?
  • You are an importer if you buy a chemical product directly from a supplier based outside of GB and you are legally responsible for bringing the substance into GB.
  • As an importer you have obligations for registration of these chemical substances under UK REACH.
  • Each separate legal entity importing product has the obligation to register under REACH including affiliates.
  • For the DUIN, each separate legal entity will need to complete their own notification, by having their own 'comply with UK REACH' account. The DUIN reference number is specific to the legal entity importing the substance, even if using the same OR.
  • You are not an importer if you buy substances from a supplier within the UK who has imported the substance(s) themselves.
How does UK REACH differ from EU REACH?

There is no difference in the main body of the regulation, requirements or exemptions (such as the exemptions that exist for food and feeding stuff, polymers and naturally occurring substances). These have been retained in UK REACH, which was a direct 'lift and shift' of EU REACH as it existed on 31 December 2020.

In addition, all authorisations and restrictions have been retained in UK REACH as they were under EU REACH on 31 December 2020.

Moving forward, the UK will operate independently and take its own decisions on SVHC, authorisations, restrictions and any amendments. These will not necessarily align with EU REACH.

Is the list of UK REACH grandfathered and DUIN notified substances publicly available?
  • In October 2021, the Department for Environment, Food & Rural Affairs (Defra) published the list of substances for which information was submitted as part of the grandfathering process to the Health and Safety Executive (HSE). These are the EU REACH registrations held by GB-based businesses that were directly grandfathered into UK REACH. You can view the list hereIrrespective of this list, for those importing substances in quantities greater than 1 tonne per annum into GB, the obligation to register substances remains. 
  • The list of DUIN substances is not available or shared publicly.
  • Only grandfathered substances and those that undergo the inquiry process are added to substance groups to facilitate data sharing. The members of these substance groups are shared between members.

If you have any queries regarding the DUIN or grandfather status of your substances, you should speak to your supplier.

Are importers who carry out DUIN obliged to register the substances notified in the DUIN?

There is no obligation to complete a full UK REACH registration after completing a DUIN. The DUIN allows importers time to review their supply chains and decide if they need to complete a full registration during the transitional measures, which defers the registration obligation for up to 6 years.

Different DUIN scenarios

I’m not sure if my suppliers have or will submit a DUIN?
  • The importer does not need to submit the DUIN if this has already been covered by your supplier, your supplier will be able to advise you if your substances have been notified.
  • If you are aware that your suppliers will not complete the DUIN, you should review your supply chain so that you are able to import these substances and complete the DUIN yourselves.

If you are in any doubt, we recommend that you submit a DUIN. By doing so you then benefit from the transitional measures and can continue importing your substance for up to 6 years.

Can DUINs be submitted for substances currently imported at less than 1 tonne per annum ?

As the obligation to register only applies to substances imported at greater than 1 tonne per annum, you do not need to submit a DUIN.

However, should you anticipate future growth and expect your imports to exceed 1 tonne per annum, you can submit a DUIN for those substances to take this into account.

If we are buying chemicals from a UK based supplier, are DUINs the suppliers responsibility?

You do not have UK REACH registration obligations and are not required to submit a DUIN. However, it is prudent to check that your suppliers have completed their notifications accordingly and that the substances will be registered under UK REACH.

What are UK REACH obligations for Northern Ireland?

UK REACH doesn’t apply to Northern Ireland (NI). The Northern Ireland (NI) Protocol state that NI businesses will remain within EU REACH, which means there is no need to complete DUINs for imports into NI. It is important to note that imports into NI from GB must comply with EU REACH.

Although GB and UK are often used interchangeably, GB refers to England, Wales and Scotland while UK incudes Northern Ireland. Under UK REACH we need to make the distinction between GB based companies and the GB market.

We import polymers. How do we comply with UK REACH? Do we need to submit the DUIN for the monomers?

The UK REACH registration regarding polymers (and their monomers) is the same as EU REACH. Whilst the polymers themselves are exempt from registration, the monomers are subject to registration.

If you import polymers in GB, you will need to complete a DUIN for the monomers in order to continue this activity.

Practicalities of DUIN

Do I need to submit a DUIN for a mixture?
  • Only substances need to be registered under UK REACH. When substances are present in mixtures and imported or manufactured in quantities of greater than 1 tonne, then the registration for that substance applies. 
  • When importing mixtures, each individual substance in the mixture should be included in the DUIN if they are individually imported at >1 tonne per annum. 
  • You must list all the substances within the mixture that you are aware of. 
What information is mandatory on the DUIN spreadsheet?
  • There are only two mandatory columns required to be completed on the DUIN spreadsheet, the DUIN reference number and the legal entity name. The remaining information is not mandatory. The UK authorities do anticipate that some information will be missing from submitted notifications.
  • We recommend that as a minimum, the substance name and its identifiers are included wherever known. Bear in mind that it will not be possible to complete a full UK REACH registration without knowing the substance identity, therefore you should also consider how you will meet the registration obligations at the end of the transitional deadlines.

You can also watch the step by step video below on how you can fill in the DUIN spreadsheet and submit this to the Health and Safety Executive (HSE).

What happens after I submit the DUIN to the HSE?
  • You will receive a notification from the HSE to confirm your DUIN notification and spreadsheet has been received.
  • You will not be added to a substance group at this stage. In order to complete a full registration, you will need to submit an inquiry dossier as this is the first step in the process for registration to UK REACH.
  • Your deadlines for completing the full registration will depend upon the tonnages and hazard profile of the substances you need to register.
Can I update or resubmit my DUIN, for example if I do not submit all my substances at the same time?

Once you have generated your DUIN reference number this will be used for all substances you intend to notify. You can submit subsequent spreadsheets to the HSE should you need to add more substances to your notification.