DUIN, grandfathering and NRES
Three transitional routes were created at EU exit so that chemicals already legally on the market did not stop moving on 1 January 2021. Which one applies to you determines whether you have until 2029, or whether you needed a registration yesterday.
The three routes at a glance
| Route | Who it was for | Effect |
|---|---|---|
| Grandfathering | GB-based companies that held an EU REACH registration in their own name on 31 December 2020 | The EU registration was carried into UK REACH. Full data submission deferred to the transitional deadline. |
| DUIN | GB companies that were downstream users or distributors of EU REACH registered substances, and became importers when GB left the EU | Import could continue. Registration deferred to the transitional deadline. |
| NRES | Anyone outside the two routes above who needs to place an existing substance on the GB market | A full new registration, required before manufacture or import at ≥1 t/y. No transitional period. |
Grandfathering
GB companies that held EU REACH registrations had to notify HSE of the basic details by 30 April 2021. Doing so converted the EU registration into a UK REACH registration in principle, with the underlying technical data owed later.
The critical and widely misunderstood point: grandfathering carried the registration, not the data. The full technical dossier and, where applicable, the chemical safety report still have to be submitted to HSE by your transitional deadline. Companies that treated the 2021 notification as completion have a substantial project still ahead of them.
DUIN — Downstream User Import Notification
Before exit, a GB company buying from an EU supplier was a downstream user, with no registration duty. After exit, that same purchase became an import into Great Britain — and the company became a registrant overnight.
DUIN was the relief. Companies in this position could notify HSE by 27 October 2021 and continue importing, with the registration obligation deferred to the transitional deadline for their tonnage band.
DUIN deferred your obligation. It did not remove it.
If you hold a DUIN, you owe a full UK REACH registration by 27 October 2029, 2030 or 2031 depending on your band. The notification bought time to build a dossier; it is not itself a registration and it does not become one by the passage of time.
What a DUIN covers, and what it does not
- It covers the notifying legal entity, for the substances notified, up to the tonnage indicated.
- It does not transfer to a group company, a successor entity after restructuring, or a new supplier arrangement without review.
- It does not cover substances you began importing after notification.
- It does not cover an increase into a higher tonnage band without an update.
- It does not relieve GB CLP, safety data sheet or downstream user duties, all of which apply now.
If you missed the deadline — the NRES route
New Registration of an Existing Substance is the route for a substance that exists on the market but for which you hold neither a grandfathered registration nor a DUIN. It is a full UK REACH registration under the ordinary rules.
The consequence is timing. There is no 2029 deferral. The registration must be submitted and pass completeness before you manufacture or import at one tonne a year or more. If you are importing now without one, you are importing without a valid registration.
There may still be a way back into the transitional regime
HSE has indicated that a late notification can still be made in certain circumstances by companies that were eligible to submit a DUIN and did not. Eligibility is fact-specific and the position has changed over time. If you think you should have submitted one, this is worth checking before you assume the NRES route and its costs — send us the details.
Work out where you stand
Answer these in order. The first "no" tells you which route you are on.
Did your GB entity hold an EU REACH registration in its own name on 31 December 2020, and notify HSE by 30 April 2021?
Yes → grandfathered. Data owed by your transitional deadline.
Were you a GB downstream user or distributor who submitted a DUIN by 27 October 2021?
Yes → deferred. Registration owed by your transitional deadline.
Neither?
NRES. Registration required before import or manufacture at ≥1 t/y — unless the substance is exempt or covered by an Only Representative.
General information on the UK REACH transitional routes. Eligibility for late notification and the treatment of corporate restructuring are fact-specific; confirm your position before relying on a deferral.