As we continue on the journey through UK REACH CIRS has gained invaluable practical experience. Since the beginning of UK REACH CIRS has become the Only Representative for 600+ clients globally we have also completed 500+ DUIN, assisted UK clients by Grandfathering 70+ registration, and completed the Full registration of 20+ substances on behalf of our clients. Over the last year, this experience coupled with the continuous communication with the HSE has allowed us to remain up to date with all the developments and nuances of the UK REACH requirements. CIRS would like to share the information we have gathered to date as well as the latest information that has come out from the HSE in recent weeks.
Lessons From our Practical Experience
As previously mentioned, CIRS has processed over 500 DUIN applications and completed the full registration of over 20 substances on behalf of our clients. In our experience, any company that has processed or may in the future process a UK REACH registration should consider the following points.
The DUIN has been available to both Non-UK and UK based companies to register their substances if they fulfill the following criteria
- The company is a Non-UK Manufacturer or Formulator that holds an EU REACH registration for the target substance
- The company is a UK-based importer who was importing from an EU REACH registered supplier.
- The target substances had been supplied between the 31st of January 2019 and the 1st of January 2021.
The DUIN deadline officially passed on the 27th of October 2021, meaning that any company that continues to place any substance on the UK market that has not been registered is non-compliant with the regulations. However, the authorities are still accepting applications to allow companies to become compliant as the portal remains open for now.
The New Registration for Existing Substances (NRES) Process
The NRES is required for any substance that does not meet the requirements for grandfathering, the DUIN, or situations seen in the above sections, to allow these substances to become compliant and prevent limitations on the UK market. The process has two distinct aspects which must be considered when determining if the NRES is required.
- EU registered materials
- Non-EU registered materials
Both require the submission of an Article 26 inquiry to begin the process the paths then diverge depending on the registration status of the substance. Following this, the full registration data will be required to obtain the registration number. The UK authorities do recognise that the full data will not be immediately available and have allowed on a case-by-case basis the submission of a data waiver deferring the submission of the full data but allowing access to the registration for that registrant.
Our UK REACH Service
- Down Stream User Notification (DUIN)
- Only Representative (OR) Service
- Lead Registrant
- Joint Submission
- Chemical Safety Report (CSR) Compilation
- Testing Coordination/Supervision
- Alternative methods (QSAR, Read-Across, In-vitro, Grouping, etc.)
- SIEF Management Service
- Development of Exposure Scenario (ES)
If you have any questions or would like to enquire about any of the services we can offer your business, please feel free to contact us as we would be happy to help.
Senior Regulatory Consultant in CIRS Europe
Phone: +00 353 (1) 477 3706