The Downstream User Import Notification (DUIN) system, introduced under UK REACH after Brexit, was designed to ease the transition for UK chemical importers. It allowed companies that had already imported a substance, or were downstream users under EU REACH, to continue importing without immediately completing full registration. But what was intended as a pragmatic bridge has, according to BASA and others across UK industry, become a constraint on innovation and growth.
Under current rules, only businesses that imported a substance within two years before 1 January 2021 qualify for DUIN. Any company wishing to bring in a new or previously unimported substance must instead use the more complex and costly New Registration of Existing Substances (NRES) route. This system, BASA argues, effectively locks UK companies into pre-2021 substance portfolios and stifles access to new or greener chemistries.
Industry voices have expressed growing frustration. As the company SC Johnston notes, the restriction “inhibits innovation at a time when it should be supported.” The British Coatings Federation echoes the concern, warning that the NRES procedure “is effectively freezing the UK market for many manufacturers.”
The NRES process, while technically an option, can take months to complete and demands extensive data, dossier preparation, and fees for Letters of Access to existing studies, all of which place heavy burdens on SMEs and innovators. For many smaller businesses, the costs and delays are prohibitive, making it easier to continue with existing products rather than pursue new formulations. As a result, what began as a mechanism to ensure continuity has turned into a roadblock for progress. Without reform, UK companies risk losing ground to international competitors operating in more agile regulatory environments.
BASA is calling for an extension of the DUIN process to include substances already registered under EU REACH, even if not previously imported into Great Britain. Such a move, we argue, would help level the playing field, encourage investment, and restore momentum to an industry critical to the UK’s manufacturing base without any reduction in safety. Read the full article at https://members.basa.uk.com/news/Details/from-innovation-to-inaction-the-duin-drag-on-uk-business-298248.
BASA is the UK’s independent voice for the £1.7 billion adhesives and sealants sector in the UK and Ireland, representing members through advocacy, technical guidance, and networking. We champion innovation, compliance, and sustainability while supporting business growth and strengthening industry standards. Visit us at www.basa.uk.com.
