The deadline for registering as a downstream user in Great Britain under UK REACH is quickly approaching, as the Brexit transition period finally comes to a close. Downstream users and distributors based in Great Britain will need to notify the HSE of their status by August 23, 2021 in order to continue importing products into the country.
GB-based companies that were considered downstream users or distributors under EU REACH will now be considered importers at the point when UK REACH enters into force.
This notification needs to be done in order to receive a UK REACH DUIN number. This number will be necessary when informing the HSE about the products companies want to import into the country. By completing the notification, companies can avail of a transition period to complete their obligations under UK REACH. If the deadline to notify as a DUIN on 23rd August 2021 is missed, either a full registration would be due for any substances imported at or above 1 tonne per year, or that import must cease.
Now that the Brexit transition period is ending, the new regulation will impact any legal entity which intends to import at-or-above 1 tonne of a substance from the EU into the United Kingdom. However, downstream users and distributors who inform the HSE of their status within 300 days from the end of the transition period will be able to effectively defer registration. This period of time could be as long as six years, with the additional 300 days given since the announcement was made.
This significant time period has been granted in order to minimize disruption to businesses. However, in order to avail of this lengthy time period organizations need to register their status before the deadline.
Contacting the HSE will be necessary for four different categories of businesses.
- British companies importing into the country from the EU who intend to continue after the end of the transition period
- British companies importing into the country from outside of the EU under an ‘Only Representative’ (OR) agreement who intend to continue after the end of the transition period
- Non-British companies that want to appoint a British OR after the end of the transition period
- Businesses who were not previously downstream users and who plan to import into the country for the first time
Non-GB based manufacturers can appoint an OR based in Great Britain to submit notifications under UK REACH on their behalf. Deenamic Ltd’s London office
At Deenamic Ltd, we provide UK and EU REACH services to our clients. You can reach out to us at firstname.lastname@example.org for a preliminary consultation and find out how our organization can help you navigate regulatory compliance.