Important updates on UK REACH: Inquiry rational and Lead Registrant selection

Date: 18 March 2021

Inquiry after DUIN explained by HSE

At the end of December 2020, the UK REACH authorities, HSE, indicated that the Downstream User Import Notification (DUIN) for UK based importers or distributors has to be followed by an Article 26 inquiry. However, there was a general lack of clarity regarding the purpose of this inquiry. Recently the HSE has published new guidance explaining the function of the inquiry step.

A successful DUIN entitles the notifier to defer the registration of their substance until the end of the relevant registration deadlines. The DUIN therefore allows the continued placing on the market and use of the notified substance in the UK for another 2, 4 or 6 years after the DUIN deadline of October 27, 2021.

The Article 26 inquiry step ensures that potential registrants have been assigned to the correct substance groups after notification. For example, importers might have submitted a DUIN for substances that they do not need to register. Having the inquiry step ensures the substance groups only comprise of potential registrants who are required to be in these groups.


KKDIK regulation now moving into registration phase: important updates on the Lead Registrant selection

Date: 23 February 2021

With the end of the pre-registration phase for KKDIK (‘Turkey REACH’) on 31 December 2020, full attention has now shifted to the actual registration phase, a 3-year window until 31 December 2023.

The Turkish Ministry of Environment and Urbanization (MoEU) recently published a number of updates to inform all actors in the supply chains on important details for the next phase.

Companies that consider becoming Lead Registrant (LR) for a pre-registered substance should clarify their intention soon and be ready to communicate their position with other SIEF members in the coming weeks. The Lead Registrant selection process has started and Lead Registrant candidates need to approach the other SIEF members for acceptance of the LR role. While LR voting is not compulsory, a voting module will be integrated on the SIEF page for the selection of the Lead Registrant in case of SIEF disagreement. The declarations for the Lead Registrant will start on 1 March 2021, simultaneously with the integration of the voting module in the KKS system.


New EU Fertiliser Regulation – notifying body for Germany and Nando

Date: 16 February 2021

The new EU Fertiliser Product Regulation 2019/1009 of the European Parliament and of the Council of 5 June 2019 is intended to create harmonized conditions for the supply of fertilisers across the internal market and to define general principles for CE marking.


HSE is operating an independent PPP active substance renewal programme for Great Britain

Date: 12 February 2021

In its newsletter on 11 February, HSE informs about a PPP active substance renewal programme for Great Britain that is independent of the EU and in operation from 1 January 2021. You can find the list of active substances, their expiry dates and the relevant renewal application deadlines on the HSE website.

SCC and GBK are cooperation partners offering consolidated expertise and bundled services

Date: 2 February 2021

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With the newly enhanced cooperation, SCC and GBK bundle their vast expertise in legal, environmental, health, safety and regulatory issues to offer their customers versatile and integrated services across the world.

SCC supports its international customers with cost-efficient tailored solutions for their scientific and regulatory needs in the fields of agrochemicals, and biorationals, fertilisers, chemicals and biocides, feed and food additives, food contact materials, cosmetics and consumer products, medical devices, pharmaceuticals and legal services (provided by SCC Legal).

GBK GmbH Global Regulatory Compliance, Ingelheim, is an international consulting company providing a hands-on expertise in the fields of environment, health and safety to their more than 1,250 global customers in the chemical, food, pharmaceutical and automotive industries. GBK’s core services include product-registration in chemical inventory lists in Europe, USA and Asia, EHS auditing and dangerous goods services, including worldwide EMTEL emergency phone service for hazardous materials transportations as well as seminars and trainings. For more information on GBK, please visit GBK’s website.