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Pre-Registration Deadline Approaching: Korea-REACH

March 2019 --

As more countries implement chemical regulations, they look to the EU REACH as a model to emulate. Korea is one of these countries. On Jan 1, 2019 the Korean REACH regulation more commonly known as K-REACH, begins. If you are familiar with EU REACH then the K-REACH program will not pose many surprises, however there are a few differences that you should be aware of.

Korea has taken a proactive measure to create a list of Existing Chemical Substances which they consider on the market. The K-REACH pre-registration process calls out that all manufacturers/imports of these Existing Chemical substances must notify or “pre-register” the substance if that substance is imported in quantities greater than 1 MT/yr.  In addition, the “pre-registration” must be completed for any “New” substances prior to importation if they are < 100 kg/yr. For “New” substances to be imported > 100kg registration must be completed prior to importation.

Type

Obligation

New substance Imported/Manf < 100kg/yr

Notification prior to manufacture/import (No hazard data requirement)

New substance Imported/Manf > 100kg/yr

Registration prior to manufacture/import (Hazard evaluation required)

Existing Substances Imported/Manf > 1 MT/yr

  • Pre-notification between 1 Jan 2019 and 30 Jun 2019
  • Registration within given grace periods

 

The notification process entails the submission of company info, substance name, volume, classification and use info to the Korean Ministry of Environment (MoE). Registration involves the same information as well as the physiochemical, Toxicological, Ecotox and hazard assessments that are common with the EU REACH registrations. Some substances depending on intended market of use, naturally occurring, or covered by other regulations can qualify for exemption to registration. Depending on the exemption it may be self-declaring or require confirmation by the MoE. An obvious applicable exemption that exist for many of our products is for “gunpowder and military supplies”. This is a self judgement exemption and if applicable should be claimed on all import declarations. Importers must utilize an in-country representative to submit chemical registrations on their behalf, similar to the REACH Only Representative.

As an immediate action one should review all substance imports into Korea and determine if those substances meet any of the following criteria:

  • Substance and/or use qualifies for an exemption
  • Status of the substance (on/off) the Existing Chemical List
  • Estimate of 2019 annual imports and importation dates

Depending on the findings one can determine if the pre-registration requirements must be met prior to the June 30, 2019 deadline.