NRES: The alternative to DUINs for the registration of new flows

NRES: The alternative to DUINs for the registration of new flows

mardi 28 septembre 2021
The Acronym NRES, New Registration of an Existing Substance, is composed of two parts:
• New registration – registration of a substance that has not been placed on the market by that specific company prior to 31st December 2020
• Existing substance – a substance that has already been registered by a registrant under EU REACH

An NRES enables companies that have registered a substance under EU REACH after 31st December 2020 or that started to buy, after the 31st December 2020, a substance registered under EU REACH, to import the substance in Great Britain for quantities above one ton per year.

The NRES is subjected by UK REACH Article 26.

To submit an NRES, you must first submit an Inquiry according to the following process:
1. Gather analytical data to correctly identify the substance.
2. Create an Inquiry dossier with Iuclid.
3. Create an account on “ Comply with UK REACH ”and submit the dossier.

The validation of the Inquiry by the authorities gives access to the “substance group” and enables to get information about other registrants. You need then to submit the registration:
1. Complete the Inquiry dossier with the additional required information.
2. Submit the registration on Comply with UK REACH.
3. Pay the UK REACH registration fees.

Currently, the discussions to gather the data submitted by the Lead Registrant under EU REACH are still in progress and it is therefore not possible to use them. Consequently, the dossiers must include a “waiver statement” explaining why the registrants cannot give all the information and indicating that they will negotiate with the other members of the “Substance Group” to get them. The registrants will have a delay depending on the hazard class of the substance and on the tonnage manufactured or imported to submit the full registration dossier:

Deadline (last date for dossier submission): 27 October 2023
Tonnage: 1000 tons or more per year
Hazardous property:
• Carcinogenic, mutagenic or toxic for reproduction (CMRs) - 1 ton or more per year
• Very toxic to aquatic organisms (acute or chronic) - 100 tons or more per year
• Candidate list substances (as at 31 December 2020)

Deadline (last date for dossier submission): 27 October 2025
Tonnage: 100 tons or more per year Candidate list substances (as at 27 October 2023)

Deadline (last date for dossier submission): 27 October 2027
Tonnage: 1 ton or more per year

Once fees have been paid to HSE, a confirmation from the authorities will be given to you within 3 weeks. You will then be able to import the substance above 1 ton.

If you need more information or help about this process, Lisam Telegis can guide you through this process.

 

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