Notification of status as a GB-based downstream user or distributor under EU REACH

Any GB-based legal entity continuing to import a substance into Great Britain (England, Scotland and Wales) at or above 1 tonne per year must submit a registration to HSE for that substance (unless an exemption applies). This obligation to register includes the import of substances from the EU.

If in the 2 years prior to 1 January 2021 you were a downstream user or distributor under EU REACH, or you were regarded as a downstream user by virtue of an Only Representative (OR) agreement, your registration obligation is deferred until 27 October 2026, 27 October 2028 or 27 October 2030, depending on the tonnage band or hazard profile. You should have supported this deferral by submitting a downstream user import notification (DUIN) before 27 October 2021 (300 days from January 2021).

If you did not notify HSE and wish to continue to import EU REACH registered substances into Great Britain at or above one tonne per year, you can still submit a notification, if eligible to do so. You should do this as soon as possible.

If you were not previously a registrant, downstream user or distributor under EU REACH, and you wish to import chemicals into Great Britain for the first time, at or above one tonne per year, you may need to submit a new registration under UK REACH.

Who is this guidance for?

• GB-based legal entities that were downstream users or distributors of substances and mixtures under EU REACH prior to 1 January 2021 who want to import those substances or mixtures into Great Britain after 1 January 2021
• GB-based legal entities that were importing substances and mixtures into Great Britain from outside of the EU, under an OR agreement held by an EU-based entity prior to 1 January 2021 and have continued to import after 1 January 2021
• Manufacturers, formulators and article producers based outside of Great Britain that wish to appoint a GB-based OR to notify on behalf of their GB-based customers that were importing substances and mixtures prior to 1 January 2021 as a downstream user or distributor under EU REACH and have continued to import after 1 January 2021

Downstream User Import Notification (DUIN)

To benefit from the deferred registration deadline, GB-based companies that were downstream users and distributors prior to the end of the transition period under EU REACH must notify HSE about the substances that they wish to continue importing into Great Britain from the EU at or above one tonne per year.

If you do not submit a notification, then either a full registration may be due for any substances imported at or above 1 tonne per year, or your import into Great Britain must cease or be below one tonne per year.

Non-GB based manufacturers, formulators or article producers can appoint a GB-based OR to submit notifications on behalf of their GB-based importers where those GB-based importers were entitled to submit a notification (for example the GB-based importer had been a downstream user or distributor under EU REACH for that substance in the 2 years prior to 1 January 2021). If the GB-based importer was not entitled  to submit a notification then an OR cannot submit a valid notification on their behalf and a new registration may be required before an import into GB at or above one tonne per year. GB-based importers that were regarded as downstream users due to the appointment of an EU-based OR (under EU REACH) are also able to notify. A newly appointed GB-based OR can also make this notification on their behalf.

A downstream user import notification (DUIN) is not a pre-registration. The concept of pre-registrations does not exist under UK REACH.

Having submitted a DUIN, you are not obliged to register unless you wish to continue importing the notified substance after 27 October 2026, 27 October 2028 or 27 October 2030. The registration deadlines are dependent on the tonnage and hazard profile of the substance.

Make a Downstream User Import Notification

To submit a DUIN:

1. use the Comply with UK REACH service on GOV.UK to indicate that you are an existing downstream user or distributor or a GB-based OR submitting a notification on behalf of a downstream user or distributor. Notification only needs to be done once per legal entity and covers all substances that entity wishes to continue importing from the EU. You'll be issued a unique UK REACH DUIN number for each notification submitted.
2. populate the downstream user import notification with information about the substances that you wish to continue to import.
   Use the template
3. send the completed spreadsheet to [email protected] and include your legal entity name and DUIN number in the subject line of the email.

Substances in mixtures

Only substances should be notified; not mixtures (formulations). If you import mixtures, you only need to notify the individual substances within those mixtures if any will be imported at or above one tonne per year.

If substance information is not available

Information about a substance only needs to be submitted if it is available to you. This is of relevance to importers of mixtures, where your supplier may not wish to divulge the composition of their products.

After you've made a notification

If you wish to continue importing into Great Britain from the EU after 27 October 2026, 27 October 2028 or 27 October 2030, depending on the tonnage band or hazard profile, you must submit a new registration to HSE for each substance that you wish to continue importing after the relevant deadline (there is more information in the table below), complying with the full information requirement for your tonnage band. Under UK REACH the first step to any new registration is to submit an Article 26 inquiry. The information requirements for registration under UK REACH are identical to the requirements of EU REACH.
It is expected that where there are multiple registrants for a substance, this information will be submitted jointly. ECHA's guidance on data-sharing remains a useful document.

UK REACH tonnage bands and hazard profiles