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UK REACH entered into force on 1 January 2021, with the post-Brexit landscape characterised by changes to roles and obligations, a level of uncertainty to business continuity and supply of chemicals (including cosmetic ingredients). This has especially affected Downstream Users (DUs) of chemicals, which the majority of cosmetic businesses can identify with. Many DUs are now importers of chemicals from the EU, or from other third countries, meaning that they must submit a Downstream User Import Notification (DUIN) by 28 October 2021 to comply with UK REACH.
In order to submit the DUIN, the below is the information required under UK REACH:
- identity of the manufacturer/importer;
- identity of the substance;
- classification and labelling of the substance, only if the information is available;
- EU REACH registration number, only if the information is available;
- substance authorisation, if applicable;
- substance restriction, if applicable;
- any other available and relevant information to manage risks.
In practice you have to
- Use the Comply with UK REACH service to register as an existing downstream user or distributor. The system will provide you with a UK REACH DUIN number; this only needs to be done once per legal entity and covers all substances that you wish to continue importing from the EU.
- Populate the additional information spreadsheet template (.xlsx) with information about the substances that you wish to continue importing. The spreadsheet should list individually all of the substances that you wish to continue importing from the EU, one per line. The spreadsheet must contain at least one of the following identifiers: substance name, CAS number, EC number.
- Send the completed spreadsheet to the Agency at [email protected]. You should include your legal entity name and DUIN number in the subject line of the email. It may be easier to fulfil some of the information requirements by attaching a Safety Data Sheet (SDS) to the email rather than including it in the spreadsheet.
CTPA advises all companies importing chemicals from the EU to submit DUINs to ensure continuity of supply until the UK REACH deadlines for full registration.
To find out more about UK REACH, check the below infographics and the CTPA guide of post-Brexit Trade