必胜娱乐网址

Introduction

As we continue on the journey through 必胜娱乐网址必胜娱乐网址 CIRS has gained invaluable practical experience. Since the beginning of 必胜娱乐网址必胜娱乐网址 CIRS has become the Only Representative for 600+ clients globally we have also completed 500+ DUIN, assisted 必胜娱乐网址 clients by Grandfathering 70+ registration, and completed the Full registration of 20+ substances on behalf of our clients. Over the last year, this experience coupled with the continuous communication with the HSE has allowed us to remain up to date with all the developments and nuances of the 必胜娱乐网址必胜娱乐网址 requirements. CIRS would like to share the information we have gathered to date as well as the latest information that has come out from the HSE in recent weeks.

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As previously mentioned, CIRS has processed over 500 DUIN applications and completed the full registration of over 20 substances on behalf of our clients. In our experience, any company that has processed or may in the future process a 必胜娱乐网址必胜娱乐网址 registration should consider the following points.

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必胜娱乐网址必胜娱乐网址 as a whole is currently in a transition period where the full registration of chemical substances will be completed on a phased basis depending on the hazardous nature of the substance and the quantity of that substance being placed on the 必胜娱乐网址 market. This system aims to ensure that for suppliers and downstream users their businesses will remain largely unaffected during this time and allow trade as was seen under EU 必胜娱乐网址. Substances that were registered by 必胜娱乐网址s under EU 必胜娱乐网址 and then who processed Grandfathering or DUIN for those substances are considered “Protected Transitional Substances”. The 必胜娱乐网址必胜娱乐网址 regulations for this, specifically link 必胜娱乐网址s to Customers and 必胜娱乐网址必胜娱乐网址 to EU 必胜娱乐网址s. These vital details mean that changing supplier during the “必胜娱乐网址必胜娱乐网址 Transitional Phase” is NOT a simple and easy process.

Due to this, two common scenarios may arise, which suppliers and customers should be aware of.

Scenario 1: Non-必胜娱乐网址 based manufacturer or formulator has appointed a 必胜娱乐网址-based OR, who then undertook the requisite DUIN Notification on their behalf. The non-必胜娱乐网址 company would like to supply a new 必胜娱乐网址-based company that they have never supplied before.

The DUIN process was allowed because of the existing supply chain between the non-必胜娱乐网址 supplier and the 必胜娱乐网址-based customer. Therefore, the 必胜娱乐网址, OR, and Customer are all linked under the definition of “Protected Transitional Imports” as the Product was EU registered with Existing 必胜娱乐网址/GB customer and the Product had been supplied between the 31st of January 2019 and the 1st of January 2021.

As the non-必胜娱乐网址 company has never supplied this ‘New’ 必胜娱乐网址 customer before they do not meet the requirements of DUIN. Additionally, the Non-必胜娱乐网址 entity would not be able to rely on the OR’s DUIN notification as the product would not benefit from ‘protected transitional import status’ and the NRES process will apply in order to be able to supply this ‘New’ customer.

Scenario 2: 必胜娱乐网址-based entity imported EU 必胜娱乐网址 registered products they undertook a DUIN Notification themselves and would now like to change supplier of their product.

As seen in Scenario 1 the DUIN process was allowed because of the existing supply chain between the non-必胜娱乐网址 supplier and the 必胜娱乐网址-based customer. The customer/importer benefits from “Protected Transitional Imports” status as the Product was EU registered with an Existing 必胜娱乐网址/GB customer and the Product had been supplied between the 31st of January 2019 and the 1st of January 2021.

The 必胜娱乐网址-based customer’s DUIN allows them to purchase from an alternative source so long as the new supplier of the product is registered within the EU 必胜娱乐网址 system. If they wish to purchase from a company that does not have an EU 必胜娱乐网址 registration for the product, then the NRES process will apply.

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Down Stream User Notification (DUIN)
Only Representative (OR) Service
Lead Registrant
Joint Submission
必胜娱乐网址 Safety Report (CSR) Compilation
Testing Coordination/Supervision
Alternative methods (QSAR, Read-Across, In-vitro, Grouping, etc.)
SIEF Management Service
Development of Exposure Scenario (ES)
Training

If you have any questions or would like to enquire about any of the services we can offer your business, please feel free to contact us as we would be happy to help.

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The Latest 必胜娱乐网址必胜娱乐网址必胜娱乐网址 - DUIN 必胜娱乐网址 and the NRES Process

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Dean Winder

Senior Regulatory Consultant in CIRS Europe

Email:[email protected]

Phone: +00 353 (1) 477 3706

We have launched a LinkedIn newsletter to keep you up to date on the latest developments across the chemical industry including food and FCMs and personal and home care.

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Introduction

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